STATE OF CALIFORNIA-THE RESOURCES AGENCY ' VOICE...

\ STATE OF CALIFORNIA-THE RESOURCES AGENCY }?£.:CORD PACKET COPY PETE WILSON, Governor

· - CAliFORNIA COASTAL COMMISSION "' 45 FREMONT, SUITE 2000

SAN FRANCISCO, CA 94105·2219 VOICE AND TOO (4 I 5) 904·5200 Tu 13c, 13d, 13e

Date Filed: 49th Day: Staff: Staff Report: Hearing Date: Item Nos.: Commission Action: Commission Vote:

March 21, 1996 May 8, 1996 AD/JML-SF March 21, 1996 April 9, 1996 13c, 13d, 13e

REGULAR CALENDAR: STAFF RECOMMENDATION

Permit Numbers:

Applicants:

Agent:

Project Description:

Approvals Received:

Substantive File Documents:

E-95-12, E-95-13, E-95-14

Union Oil Company of California (E-95-12) Texaco Exploration & Production Inc. (E-95-13) Chevron U.S.A. (E-95-14)

Simon Poulter, Fugro West, Inc.

Unocal: Abandon six subsea completion oil wells (Well Nos. 1-6, 3-6, 5-6, 6-6, 8-6, and H-1) in State waters (PRC 2879) 1,200 to 13,500 feet offshore of Point Conception, Santa Barbara County.

Texaco: Abandon one subsea completion oil well (Jade East Well No. 1) in State waters (PRC 2726) 7,100 feet offshore, approximately six miles east of Point Conception area, Santa Barbara County.

Chevron: Abandon three subsea completion oil wells (Well Nos. 51, 52, and 53) in State waters (PRC 1824) 5,800 feet offshore of Summerland, Santa Barbara County. (See Exhibit 1)

State Lands Commission certified EIR No. 663 (No. 94121042) and approved the Santa Barbara Channel Subsea Well Abandonment and Flowline Abandonment/Removal Program, October 17, 1995.

See Appendix A.

CDP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron

SYNOPSIS

Union Oil Company of California ("Unocal") proposes to abandon six subsea completion oil wells (including wellhead assembly removal for Well Nos. 1-6, 3-6, 5-6, 6-6, 8-6, and H-1) in State waters (PRC 2879) 1,200 to 13,500 feet offshore of Point Conception, Santa Barbara County. The maximum duration of the Unocal project is anticipated to be 51 days. Texaco Exploration and Production Inc. ("Texaco") proposes to abandon one subsea completion oil well (including wellhead removal for Jade East Well No. 1) in State waters (PRC 2726) 7,100 feet offshore, approximately six miles east of Point Conception, Santa Barbara County. The maximum duration of the Texaco project is anticipated to be 9 days. Chevron USA ("Chevron") proposes to abandon three subsea completion oil wells (including wellhead assembly removal for Well Nos. 51, 52, and 53) in State waters (PRC 1824) 5,800 feet offshore of Summerland, Santa Barbara County. The maximum duration of the Chevron project is anticipated to be 30 days.

Unocal, Texaco, and Chevron represent three of six offshore oil and gas operators (Phillips Petroleum Company, ARCO Oil and Gas Company, CalResources LLC/Shell Western Exploration & Production Inc.(SWEPI), Union Oil Company of California (Unocal), Texaco Exploration and Production Inc. and Chevron USA) that are proposing a coordinated Santa Barbara Channel Subsea Well Abandonment and Flowline Abandonment/ Removal Program (the "Subsea Well Abandonment Program"). The overall Subsea Well Abandonment/Removal Program encompasses two phases: ( 1) permanent abandonment of 23 subsea completion oil or gas wells on nine separate State leases between Point Conception and Summerland; and (2) abandonment-in-place/removal of of 47 flowlines at three of the lease sites (Phillips, ARCO and CalResources/SWEPI). The flowline abandonment/removal phase of the program will occur during a separate 12 month period (Unocal, Texaco and Chevron do not have flowline abandonment/removal work as a part of their projects).

The Subsea Well Abandonment Program is being undertaken to comply with the well operators' State Lands Commission ("SLC") oil and gas lease provisions. The lessees are, at the request of the State, to remove all "platforms, fixed or floating structures" and "restore the premises" upon the expiration or termination of the leases. To abandon the 23 wells, the well operators propose to bring a single, shared jack-up rig to the Santa Barbara Channel. The 23 wells will be abandoned sequentially over a 12 consecutive month period. The flowline abandonment/removal phase will occur during a separate 12 month period.

Although the six well operators are contracting jointly to use a single jack-up rig, the operators consider each company's well abandonment and flowline abandonment/removal activities to be separate projects. The well operators thus submitted to the Coastal Commission seyen separate coastal development permit ("CDP") applications. This staff report evaluates the Unocal, Texaco and Chevron's projects only. The Coastal Commission approved Phillips' application E-95-9 to abandon five subsea completion gas wells and remove/abandon-in-place 27 flowlines at its March 1996 meeting.

1

COP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron Page3

Each applicant's proposed operations include (1) positioning the jack-up rig at each well site (i.e., lowering the rig's legs and anchors); (2) permanently plugging each shut-in well with cement; and (3) removing the wellhead structures for onshore disposal. The well abandonment phase is expected to take the f<?llowing amount oftime: Unocal51 days, Texaco 9 days, and Chevron 30 days.

Table 1 (pgs. 4 and 5) summarizes project-related significant issues, potential impacts and the mitigation measures and conditions that each applicant will implement to avoid, or reduce to insignificance, any impacts. The staff believes that each project, as proposed and conditioned, is consistent with Coastal Act policies. · The staff recommends approval of each project as conditioned.

,

CDP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron Page4

Table 1. Issue Summary: Potential Impacts and Proposed Mitigation Measures/Conditions

Si~riifiea'nt, bsu,e, J\.rea , ·

.. · ..••..• < > < · .. ·.. · ... · . • ... ,., •·.·.··.'

. Prol}oset~c· Mitigation .Measures/SpeCial• C,onditions/Other ..... . ... •::, ... , :· .... · .. ·· .:·'.

Oil and Gas Issue: An oil or gas release could occur from: (1) a well blowout; or (2) rig-vessel collision. Spills

Commercial /Recreational

Fishing

,

Mitigation Measures: • Each applicant will equip every well with a blowout prevention system prior to well

abandonment activities. • After each applicant completes a pre-abandonment survey (Special Condition 3) of

the work area, and before commencement of project activities, each applicant is to submit and implement a Final Anchoring Plan (Special Condition 4) that includes (1) anchoring procedures and locations, and (2) anchor preclusion zones (areas where oil and gas subsea infrastructure exists).

• Each applicant will maintain a designated standby vessel at the project site at all times equipped with 2,000 feet of boom, an 18-foot boom boat, skimmer and absorbent pads. Each applicant is also a member of the Clean Seas oil spill cooperative.

Issue: The project could result in the following economic impacts to commercial fishermen and sportfishing groups: (1) jack-up rig placement will temporarily preclude fishing in the work area, and (2) removal of the wellheads will result in a reduction oi artificial structures at which certain commercial and sportfishing occurs. The Central Coast Hook and Line Fishermen's Association, has requested that either (1) the wellheads structures be abandoned-in-place; or (2) the well operators build new deep water reefs to replace the wellheads. Mitigation Measures: • Each applicant will comply with all established vessel traffic corridors and oil service

support corridors while in the Santa Barbara Channel. • Local fishermen will be notified of project activities via a Notice to Mariners and

through Joint Oil/Fisheries Committee notification procedures. • Each applicant and the other well operators have agreed to pay compensation to

commercial hook and line fishermen for documented loss of catch associated with areal preclusion caused during rig operations at the well locations.

Other Issues: • The Commission finds that abandoning the wellheads in place is not a "feasible" project

alternative. (See section 4.3.2 of these findings.) · • The Commission does not believe that the well operators should be required to provide

mitigation for economic impacts to commercial/recreational fishermen due to the removal of wellheads placed on the seafloor for the sole purpose of oil and gas production, not fisheries enhancement. The fishermen and sportfishing groups that successfully fish at these wellhead sites have over the years derived an incidental economic benefit from the placement of these structures on the seafloor. SLC lease provisions are expressly clear that these wellheads and other oil and gas structures are to be removed upon termination or relinquishment of the leases. (See section 4.5.3)

.. CDP Appli~ation E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron

Table 1. Issue Summary: Potential Impacts and Proposed Mitigation Measures/Conditions

.. ··.... . . . .. ·· .. ·.

Ptopose(:( Miti2ation Measures/Special Conditions/Other Significant · ! , '

Issu.e . Area I ·.

Air Quality

Marine Resources

Issue: The overall Subsea Well Abandonment Program will result in a release of 90 tons NO" emissions causing significant air. quality impacts. Mitigation Measures: • Although current Santa Barbara County APCD rules and regulations exempt the Subsea

Well Abandonment Program from permitting requirements, Unocal, Texaco, Chevron and the other well operators have agreed to an "Emission Reduction Agreement" that includes payment of $748,750 to the APCD that will be used, to fund programs (such as retrofitting of trawling engines) to help mitigate the short-term air quality impacts caused by implementation of the Subsea Well Abandonment Program.

Issue: Positioning of the rig and deployment of anchors may result in unavoidable impacts to 5,000 square feet of natural hard bottom at Unocal's wells on PRC 2879. No impacts to kelp resources are expected. "' Mitigation Measures: • Each applicant has prepared an initial Anchoring Plan that proposes measures to avoid

hard bottom, where feasible, by using precision navigation equipment for rig placement and implementing an anchor and rig placement preclusion plan.

• Special Condition 3 requires each applicant's consultant to conduct a preabandonment survey of the project area to identify the location and abundance of hard bottom.

• Special Condition 4 requires each applicant to submit for executive director approval and implement a Final Anchoring Plan (based on the results of the pre-abandonment survey) that includes (1) anchoring procedures and locations, and (2) anchor preclusion zones (hard bottom and kelp areas).

• Special Condition 5 requires that within 30 days of project completion, each applicant's consultant conduct a post-abandonment survey to identify the location and quantify the extent of any disturbance to hard bottom and kelp plants caused by project activities. Within 45 days of completing the post-abandonment survey, each applicant's consultant is to submit directly to the executive director the results of the postabandonment survey and an analysis of the pre- and post-abandonment survey results.

• If a comparison of the pre- and post-abandonment surveys shows that impacts to hard bottom have occurred, Special Condition 6 requires each applicant to compensate for all adverse impacts to hard bottom through payment of a compensatory hard bottom mitigation fee to the United Anglers of Southern California (UASC). The fee will be calculated by multiplying the total square footage of adversely affected hard bottom by a compensation rate of $6.57. The fee is to be used by the UASC and the California Department of Fish and Game (CDFG), in combination with any hard bottom mitigation fees paid by the other well operators, to construct a new artificial reef or augment an existing reef within the Southern California Bight, pursuant to a Memorandum of Agreement by and between the Coastal Commission, the CDFG and the UASC (Exbt. 6)

• If the results of the pre- and post-abandonment surveys show that project activities caused statistically significant damage to kelp plants, Special Condition 7 requires

. each applicant to develop a Kelp Restoration Plan and submit it to the Commission in the form of an amendment to this permit.


TABLE OF CONTENTS

1.0 STAFF RECOMMENDATION ........................................................................................ 7

2.0 STANDARDS CONDITIONS ......................................................................................... 7

3.0 SPECIAL CONDITIONS ... ." ............................................................................................. 7

4.0 FINDINGS & DECLARATIONS ..................................................................................... 9

4.1 PROJECT BACKGROUND - "THE SUBSEA WELL ABANDONMENT PROGRAM" ....................................................................................................................... 9 4.1.1 Shared Jack-Up Rig .................................................................................................. 9 4.1.2 Separate Coastal Development Permit Applications ............................................. 1 0

4.2 PROJECT DESCRIPTION ............................................................................................... ! 0 4.3 PROJECT ALTERNATIVES ........................................................................................... 12

4.3.1 Project Alternatives Evaluated in the EIR .............................................................. l2 4.3.2 Wellhead-to Reef Alternatives ................................................................................ 12

4.4 OTHER AGENCY APPROVALS .................................................................................... 14 4.4.1 State Lands Commission ........................................................................................ l4 4.4.2 Regional Water Quality Control Board - Central Coast Region ............................. 14 4.4.3 County of Santa Barbara Air Pollution Control District ....................................... 15 4.4.4 U.S. Army Corps of Engineers .............................................................................. 15

4.5 COASTAL ACT ISSUES .................................................................................................. 16 4.5.1 Oil and Gas Spills ................................................................................................... 16 4.5.2 Marine Resources ...................................................................... : ............................ 20 4.5.3 Commercial and Recreational Fishing ..................................................................... 30 4.5.4 Air Quality ............................................................................................................. 32 4.5.5 Public Access/Recreation ....................................................................................... 34 4.5.6 Cultural Resources ................................................................................................. 35 4.5.7 Visual Resources .................................................................................................... 36 4.5.8 Section 30260 Coastal-Dependent Industrial "Override" Provision ...................... 37

5.0 California Environmental Quality Act ......................................................................... 39

Appendix A Substantive File Documents ............................................................................. .40

Appendix B Standard Conditions ........................................................................................... 44

.. CDP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron Page?

1.0 STAFF RECOMMENDATION

Approval With Conditions

The staff recommends that the Commission adopt the following resolution:

The Coastal Commission hereby grants permits E-95-12, E-95-13, and E-95-14, subject to ,the conditions below, for the proposed development on the grounds that (1) as conditioned the development will be in conformity with the provisions of Chapter 3 of the California Coastal Act of 1976 and (2) there are no feasible alternatives or feasible mitigation measures available, other than those specified in this permit, which would substantially lessen any significant adverse impact which the activity may have on the environment.

2.0 STANDARD CONDITIONS See Appendix B.

3.0 SPECIAL CONDITIONS

These permits are granted subject to the following special conditions:

1. Prior to commencement of project activities, each applicant shall notify the executive director of the Coastal Commission (hereinafter "executive director") of the drill rig each applicant shall use for well abandonment operations. If an applicant plans to use a drill rig other than the Glomar Adriatic VIII, it shall demonstrate to the satisfaction of the executive director that the operational characteristics and impacts of such other rig will be equivalent in all material respects to those of the Glomar Adriatic VIII. If in the opinion of the executive director (in consultation with the State Lands Commission and the Santa Barbara County Air Pollution Control District) the specifications of the rig are not materially equivalent to the Glomar Adriatic VIII, the applicant shall not employ such other drill rig on the project except in accordance with a Commission-approved amendment to this permit.

2. Prior to commencement of project activities, each applicant shall submit to the executive director copies of any permits or other approvals for the proposed projects required by the Army Corps of Engineers and Santa Barbara County.

3. Prior to commencement of project activities, a pre-abandonment survey of the offshore and nearshore project areas shall be completed by a consultant approved by the executive director. Each applicant shall submit to the executive director for review and approval the work plan for the pre-abandonment survey prior to its implementation. The preabandonment survey shall include but not necessarily be limited to: (1) quantification of kelp plant abundance by species, age class (i.e., new recruit, juvenile or adult) and location (i.e., on or off the flowlines) in a corridor centered over the flowline bundles and a nearby control area of the same size; (2) quantification of the number of stipes of each giant kelp

COP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron ·

(Macrocystis pyrifera)·plant encountered during the survey; (3) the location, areal extent and physical characterization (i.e., high or low relief, sand-covered, etc.) of hard bottom habitat within the project's impact zones; (4) estimates of diversity and abundance of (a) benthic species and (b) fish associated with hard bottom habitat in the project area; and (5) the burial status of the flowline segments that are proposed to be abandoned-in-place.

Within 45 days of completing the pre-abandonment survey, each applica,nt's consultant shall submit directly to the executive director a written report describing the results of the pre-abandonment survey. The executive director may for good cause grant an extension of this deadline provided that the applicant submits a written request for an extension that includes reasons for the extension and a revised timeline for submitting the preabandonment survey.

4. After the pre-abandonment survey is completed and prior to commencement of project activities, each applicant shall submit to the executive director for review and approval a Final Anchoring Plan that includes (l) anchoring procedures and locations; and (2) anchor preclusion zones (i.e., areas where the pre-abandonment survey identified the presence of hard bottom, kelp and subsea oil and gas infrastructure (e.g., flowlines)).

5. Within 30 days of project completion, each applicant's consultant (approved under Special ·Condition 3) shall complete a post-abandonment survey of the offshore project area. The applicant shall submit to the executive director for review and approval the work plan for the post-abandonment survey prior to its implementation. The post-abandonment survey shall: (1) identify the location and quantify the extent (i.e., number of square feet) of any disturbance to hard bottom areas caused by project operations; (2) identify the location and quantify the extent of any damage to kelp plants caused by project operations; and (3) verify that the project area is free of debris.

Within 45 days of completing the post-abandonment survey, each applicant's consultant shall submit directly to the executive' director a written report describing the results of the post-abandonment survey and an analysis of pre- and post-abandonment survey results to derive net project impacts to hard bottom habitat and kelp resources. The executive director may for good cause grant an extension of this deadline, provided that the applicant submits for approval by the executive director a written request for an extension that includes reasons for the extension and a revised timeline for submitting the postabandonment survey.

6. Each applicant shall compensate for all project-related adverse impacts to hard bottom habitat through payment of a compensatory hard bottom mitigation fee to be used to construct a new artificial reef or augment an existing artificial reef in State waters within the Southern California Bight. The construction of a new artificial reef, or augmentation of an existing reef, $hall be carried out pursuant to a Memorandum of Agreement (MOA) by and

.. CDP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron Page9

between the California Coastal Commission, the California Department of Fish and Game and the United Anglers of Southern California (Exhibit 6).

The amount of the compensatory hard bottom mitigation fee shall be calculated by multiplying the total square footage of adversely affected hard bottom (as determined by the pre- and post-abandonment' surveys) by a compensation rate of $6.57 per square foot. The fee shall be paid to the United Anglers of Southern California within 30 calendar days of the executive director's review and written approval of the results of the pre- and postabandonment surveys.

7. If the results of the pre- and post-abandonment surveys show that project activities caused statistically significant damage to kelp plants, the applicant shall within 60 days of completing the post-abandonment survey develop a Kelp Restoration Plan and submit it to the Commission in the form of an amendment to this permit. The executive director may for good cause grant an extension of this deadline provided that the applicant submits a written request for an extension that includes reasons for the extension and a revised timeline for submitting the amendment application.

4.0 FINDINGS AND DECLARATIONS

The Commission finds and declares as follows:

4.1 Project Background- "The Subsea Well Abandonment Program"

4.1.1 Shared Drill Rig

Six offshore oil and gas well operators, Phillips Petroleum Company, ARCO Oil and Gas Company, CalResources LLC/Shell Western Exploration & Production Inc.(SWEPI), Union Oil Company of California (Unocal), Texaco Exploration and Production Inc. and Chevron USA, are proposing a coordinated Santa Barbara Channel Subsea Well Abandonment and Flowline Abandonment/Removal Program (hereinafter referred to as the "Subsea Well Abandonment Program"). The Subsea Well Abandonment Program encompasses two phases: (1) permanent abandonment of23 subsea completion oil or gas wells on nine separate State leases between Point Conception and Summerland (including wellhead assembly removal); and (2) abandonmentin-place/removal of 47 flowlines at three of the lease sites (Phillips, ARCO and CalResoirrces/SWEPI) (See Exhibits 1, 2, and 3).

The Subsea Well Abandonment Program is being undertaken to comply with the well operators' State Lands Commission oil and gas lease provisions. The lessees are, at the request of the State, to remove all "platforms, fixed or floating structures" and "restore the premises" upon termination or relinquishment of the leases. (See, for example, SLC oil and gas lease PRC 2879.1, section 14, issued to Unocal in Apri/1962.)

COP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron

To abandon each of the 23 subsea wells, the well operators propose to bring a single, shared jackup rig1 to the Santa Barbara Channel. Under this approach, only a single rig mobilization to the Santa Barbara Channel region will be required, thereby reducing environmental impacts and lowering the costs each individual operator would incur should independent rig mobilization be pursued. At present, there is no such rig located on the western coast of the United States. The operators have not yet contracted for a drilling rig2

• However, for purposes of environmental review, the well operators chose a representative jack-up rig, the Glomar Adriatic V/11, as the type of rig to be used for well abandonment.

The rig will most likely be "dry-towed" into the Santa Barbara Channel on board a long-distance, heavy-lift vesseL Upon reaching the Santa Barbara Channel, the jack-up rig is to be floated and towed by support vessels to its destination. The jack-up rig will be supported by two workboats, one standby vessel, one tug/anchor assist vessel and one crewboat. The operators plan to abandon the 23 wells in geographic sequence, if feasible, from west-to-east. The well abandonment phase of the overall project is estimated to take 12 months to complete.

Three of the operators, ARCO (PRC 2199), Phillips (PRC 2933) and CalResources/SWEPI (PRC 2920), propose also to remove/abandon-in-place 47 flowlines{or "pipelines") that extend from wellsites to onshore processing facilities. The flowline abandonment/removal phase involves (1) abandonment-in-place of flowlines in the subtidal zone; and (2) removal of flowline segments in the nearshore shallow intertidal zone (shoreward from the 15 foot water depth).

4.1.2 Submittal of Separate Coastal Development Permit Applications

Although the six offshore oil and gas well operators are contracting jointly to bring a single jackup rig to the Santa Barbara Channel as a means to abandon the 23 subsea wells, the operators consider each company's well abandonment and flowline removal/abandonment activities to be separate projects. The six companies have submitted a total of seven individual coastal development permit ("CDP") applications for each company's respective well and flowline abandonment/removal activities. This staff report evaluates the subsea well abandonment/ removal projects ofUnocal, Texaco and Chevron only.

4.2 Project Description

Union Oil Company of California ("Unocal") proposes to abandon six subsea completion oil wells (including wellhead assembly removal for Well Nos. 1-6, 3-6, 5-6, 6-6, 8-6, and H-1) in State waters (PRC 2879) 1,200 to 13,500 feet offshore of Point Conception, Santa Barbara

1 A jack-up rig is a mobile, floating well-drilling platform that is designed to operate in shallow water generally less than 360 feet deep. Jack-up rigs have a flat-bottomed bull that is supported by a number of lattice or tubular legs. When the rig is under tow to the drilling location the legs are raised. On arrival at the drill site, the legs are lowered by electric or hydraulic jacks until they rest c:m the seabed. The platform is then jacked up above the ocean surface about 15-20 meters to provide a stable working platform.

2 The well operators plan to contract for a specific jack-up rig after all necessary discretionary permits for the Subsea Well Abandonment Program have been obtained.

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County.3 The maximum duration of the Unocal project is anticipated to be 51 days. Texaco Exploration and Production Inc. ("Texaco") proposes to abandon one subsea completion oil well (including wellhead removal for Jade East Well No. 1) in State waters (PRC 2726) 7, 100 feet offshore, approximately six miles east of Point Conception, Santa Barbara County.4 The maximum duration of the Texaco project is anticipated to be 9 days. Chevron USA ("Chevron") proposes to abandon three subsea tompletion oil wells (including wellhead assembly removal for Well Nos. 51, 52, and 53) in State waters (PRC 1824) 5,800 feet offshore of Summerland, Santa Barbara County.5 The maximum duration of the Chevron project is anticipated to be 30 days.

The wells will be abandoned with the use of a jack-up rig. (See "Background" section for discussion of drilling rig selection.) The rig will be towed to each wellsite by tugs. Proper positioning of the drilling vessel will be accomplished using a Global Positioning System and a Loran-C receiver. Once at the well site, one rig leg will be lowered to the seafloor, followed by anchor placement. After the remaining legs are lowered to the seafloor, the anchors are retrieved and the rig is preloaded (with seawater) with the maximum anticipated weight of equipment and materials to ensure adequate bottom stability. The deck will then raised to approximately 20 meters above the ocean surface.

Once the rig has been properly positioned, divers will be deployed to survey the wellhead. A protective cap constructed over the wellhead will be removed and the Blow Out Prevention Equipment will be installed to the marine riser.

Each well requires well-specific abandonment procedures due to differences in downhole characteristics, well structures at the seafloor, water depth, and other factors. A typical well abandonment includes removal of temporary well plugs, removal of the production string, and circulation of the well with drilling mud. Once the well has been prepared, permanent cement plugs will be set at specified depths. Once the well has been properly plugged, the conductor will be cut at the mudline and the riser removed. . The wellhead assembly will be disposed at an onshore disposal facility. Upon completion of the well abandonment, the jack-up rig will retract its legs and mobilize to the next well site.

3 Unocal's six subsea wells are currently inactive and non-producing. Four of the subsea wells that are capable of natural flow are currently suspended (Well No.'s l-6, 3-6, 5-6, and H-1). Well No's. 6-6 and 8-6 have been plugged and abandoned.

4 Texaco's Jade East Well No. I is currently non-producing, and it was partially abandoned in 1983 when its producing zone was cemented and plugged.

5 Chevron's three wells are non-producing and presently shut in. Also, all the associated production and hydraulic flowlines that connect Chevron's wells to Platform Hilda have been flushed and purged of oil, and disconnected from the wells. These flowlines have been partially abandoned-in-place as part of the State Waters Platform Removal Project.


4.3 Project Alternatives

4.3.1 Project Alternatives Evaluated in the EIR

In evaluating the Subsea Well Abandonment Program, the Environmental Impact Report ("EIR") identified the following project alternatives: (1) abandon wells and abandon-in-place/remove flowlines almost exclusively via offshore operations (i.e., no onshore excavation activities); (2) abandon wells using a dynamically positioned drilling vessel, with flowline removal from shore; (3) abandon wells using a dynamically positioned drilling vessel, with flowline removal from offshore; (4) abandon wells using two jack-up rigs and concurrent operations; and (5) the No Project alternative.

Based on comparative impact analyses, the EIR determined that project alternatives 1-4, as described above, would result in environmental impacts greater than the proposed project (e.g., increased air emissions, seafloor impacts and/or visual impacts). The EIR found that in the short~ the environmentally superior alternative is the No Project alternative. However, notwithstanding the No Project alternative's short-term benefits, significant long-term safety and environmental concerns accompany the No Project alternative. It is possible and likely, given sufficient time, that chronic or catastrophic releases of crude oil or natural gas could occur from subsea wellheads and associated structures as equipment reaches and exceeds its design life. The EIR therefore concludes that proper subsea well abandonment and flowline abandonment/removal is necessary from a safety and environmental perspective. The EIR identifies the proposed project as the long-term environmentally superior alternative.

4.3.2 "Wellhead-to-Reef' Alternatives

The Commission has considered also the feasibility of converting the wellhead structures to artificial reefs once the wells are properly abandoned. The Central Coast Hook & Line Fishermen's Association ("the Association") has requested that the wellheads be abandoned in place. The Association prefers that the wells be plugged permanently via the use of slantdrilling6 technology and the wellhead structures be left intact and untouched (personal communication with Phil Schenck, Central Coast Hook & Line Fishermen's Association, December 15, 1995). Another option is to abandon the wells as proposed by the well operators (which requires that the wellheads be dismantled and cut at the mudline) and place the wellheads on the seafloor next to the abandoned wellbore. The Association maintains that the economic livelihood of hook and line fishermen in the Santa Barbara Channel area is dependent in part on fishing at these wellhead sites. These potential "wellhead-to-reef' project alternatives are described and evaluated below . .

6 Also referred to as "directional drilling," slant drilling allows an operator to deflect the drilling apparatus from its vertical path. To plug a well via the use of slant drilling means that a new wellbore would be drilled, allowing the wellhead structures to be left intact and untouched.


4.3.2.1 Slant-Drilling/In-Place Abandonment of Wellheads

The Association proposes that the well operators permanently abandon their subsea wells via the use of slant drilling and leave the wellhead structures in place and undisturbed as a "fish sanctuary" for the benefit of commercial hook and line fishermen and sportfishing groups (personal communication with Phil Schenck, December 15, 1995 and letter (undated} from Phil Schenck to the Coastal Commission (received on February 20, 1996)) (Exhibit 4).

After investigating this project alternative, the Commission finds that it is not a "feasible" project alternative as defined in the Coastal Act (PRC section 30000 et. seq.). Coastal Act section 30108 defines "feasible" as "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors."

According to the California Department of Oil and Gas and Geothermal Resources ("DOGGR"), the agency responsible for regulating well abandonments, slant drilling is not a "feasible" technique to abandon properly a vertically-drilled well such as those proposed for abandonment in the Subsea Well Abandonment Program (personal communication with Bill Winkler, DOGGR, January 11, 1996). To properly and permanently seal a drill pipe in a conventional (vertical) well requires plugging directly through the wellbore, not slant drilled via a new wellbore. Also, while slant drilling has been used in the past to control a well blowout (such as the 1969 Platform A blowout), its use is technically difficult and extremely expensive (2-3 times more costly than conventional well abandonments ).

Also, to obtain State Lands Commission ("SLC") approval for such a "wellhead-to-reef' project would require an agency like the California Department ofFish and Game ("CDFG") (which administers the California Artificial Reef Program) or a group like the Central Coast Hook & Line Fishermen's Association to take ownership of the wellhead structures and indemnify the well operators against all costs and liabilities connected with the wellheads (personal communication with Dwight Sanders, SLC, January 1996). The CDFG staff has informed the Commission staff, however, that it is not interested in assuming ownership of and liability for such a "wellhead-toreef' project (personal communication with Dave Parker, CDFG, January 1996). The Central Coast Hook & Line Fishermen's Association have no financial resources available to it that would permit the group to assume the ownership of and liability for the abandoned wellhead structures (personal communication with Phil Schenck, Central Coast Hook & Line Fishermen's Association, February 27, 1996). The Commission therefore finds that this "wellhead-to-reef' concept is not a "feasible" project alternative.

4.3.2.2 Vertical Drilling/In-Place Abandonment of Wellheads

Another potential "wellhead-to-reef' project alternative is (1) to abandon the wells as proposed by the well operators (which requires that the wellhead assembly be dismantled and cut at the mudline), and (2) place the wellhead structures on the seafloor next to the abandoned wellbore.


The SLC staff has indicated that the SLC might support such a "wellhead-to-reef' concept if an agency like the CDFG or a group such as the Central Coast Hook & Line Fishermen's Association take ownership of the wellhead structures and indemnify the well operators against all costs and liabilities connected with the wellhead structures (personal communication with Dwight Sanders, SLC, January 1996). At the present time, the State of California is not willing to accept ownership of and the liability associated with leaving abandoned wellhead structures on the seafloor (personal communication with Dave Parker, CDFG, January 1996). Also, the , Central Coast Hook & Line Fishermen's Association have no financial resources available to it that would permit the group to assume the ownership of and liability for the wellhead structures. The Commission therefore finds that this "wellhead-to-reef' concept is not a "feasible" project alternative.

4.4 Other Agency Approvals

4.4.1 State Lands Commission

In 1987, Chevron submitted a proposal to the State Lands Commission ("SLC") to abandon eight subsea completion wells in the Santa Barbara Channel. As "lead agency" under the California Environmental Quality Act ("CEQA'), the SLC prepared a Negative Declaration for the eight wells. On November 7, 1991, the SLC certified Negative Declaration 563 (State Clearinghouse No. 9110100 I) and approved the abandonment of only five of the eight wells. The SLC required that an Environmental Impact Report ("EIR") be prepared for the remaining three wells located offshore of Summerland in Santa Barbara County.

The SLC subsequently received inquiries from Shell (now CalResources), Texaco, Phillips, Unocal and Arco regarding permit requirements for abandoning wells on other state leases within the Santa Barbara Channel. The SLC expanded the scope of the EIR to include an analysis of additional wells ( 18 total), the abandonment/removal of flowlines extending from Arco, CalResources and Phillips' wellheads to shore, and the deployment of a single jack-up rig to the Santa Barbara Channel to accomplish a coordinated subsea well abandonment program.

On October 17, 1995, the SLC certified EIR 663 (State Clearinghouse No. 94121042, June 1995) and approved the "Santa Barbara Channel Subsea Well Abandonment and Flowline Abandonment/Removal Program" for the remaining 18 subsea wells and associated flowlines.

4.4.2 Regional Water Quality Control Board- Central Coast Region

The Central Coast Regional Water Quality Control Board regulates marine water quality in the subsea well abandonment project area. The well operators, ARCO, Chevron, Phillips, CalResources/SWEPI, Texaco and Unocal each propose to discharge up to 225,000 gallons per day of treated sanitary wastes, kitchen and laundry graywaters, deck washdown water and desalination plant brine into the Pacific Ocean. Each applicant has chosen to individually report waste discharges to the Central Coast RWQCB and apply for an individual National Pollutant

COP Application E·95·12, E-95-13, E-95·14 Applicants: Unocal, Texaco, and Chevron

Discharge Elimination System ("NPDES") permit. The Central Coast RWQCB has issued Order No. 95-68 (NPDES Permit No. CAG283001) a limited-term General Permit for each applicant's proposed discharges associated with its subsea well abandonment project. Order No. 95-68 is described in more detail in the "Water Quality Impacts" section of this report.

4.4.3 County of Santa Barbara Air Pollution Control District (APCD)

The County of Santa Barbara Air Pollution Control District ("APCD") is the local air district responsible for implementing federal and state air quality standards in the Subsea Well Abandonment Program area. APCD Rule 202.C.2.g exempts from permit requirements piston type internal combustion engines on work-over rigs when the engines are used for the repair, work-over, maintenance or abandonment of wells. The engines on the jack-up rig and support vessels qualify for this exemption. Consequently, on November 3, 1995, the APCD determined that Unocal and Chevron's projects were exempt from APCD permit requirements (Exhibit 8). (Texaco has not applied for an exemption from the APCD.)

However, in a November 13, 1995 letter to the Coastal Commission staff, the APCD states that notwithstanding the projects' exemption from current APCD rules and regulations, the Subsea Well Abandonment Program will generate significant Class I air impacts that, if not properly mitigated, will be inconsistent with the County of Santa Barbara's adopted 1994 Clean Air Plan (Exhibit 9).

In response to the concerns raised by the APCD, Unocal, Texaco, Chevron and the other well operators have agreed to an "Emission Reduction Agreement" that includes providing the APCD with $748,750 (of this total, Unocal is to pay $163,155, Texaco is to pay $29,985, and Chevron is to pay $240,764) that will be used to fund programs (such as retrofitting trawling vessel engines) to help mitigate the short-term air quality impacts of the Subsea Well Abandonment Program (Exhibits lO and 11). (The "Emission Reduction Agreement" is described in more detail in section 4. 5. 4 of these findings.)

4.4.4 U.S. Army Corps of Engineers

On April25, 1995, the Los Angeles District of the U.S. Army Corps of Engineers ("ACOE") conditionally approved provisional permits for each of the companies Unocal (96-50022-MSJ), Texaco (95-50163-MSJ), and Chevron (94-50910-MSJ) pursuant to Section 10 of the River and Harbor Act of 1899 (33 US. C. 403) and Section 404 of the Clean Water Act ("CWA") (33 US. C. 1344). Section 10 of the River and Harbor Act regulates the diking, filling and placement of structures in navigable waterways. Section 404 of the CW A regulates disposal of dredge and fill materials into waters of the United States, including all streams to their headwaters, lakes over l 0 acres and contiguous wetlands. The permits become effective upon Coastal Commission approval of this project. Special Condition 2 requires that the each applicant submit to the Commission's executive director prior to construction a copy of the Final ACOE permit.


4.5 Coastal Act Issues

4.5.1 Oil and Gas Spills

Coastal Act section 30232 states:

-----------·---------------------

Protection against the spillCJge of crude oil, gas, petroleum products, or hazardous substances shall be provided in relation to any development or transportation of such materials. Effective containment and cleanup facilities and procedures shall be provided for accidental spills that do occur.

4.5.1.1 Potential Project-Related Oil and Gas Spills

Well abandonment activities could cause an accidental release of hydrocarbons (gas liquids or oil) into marine waters. The EIR examines a spectrum of potential accidents, called "design basis accidents (DBA)" that could occur as a result of each applicant's well abandonment operations.

Unocal: The EIR identifies three DBA's that could occur as a result ofUnocal's overall project operations: DBA 01 (rig-vessel collision during towing; 1,000 bbls fuel oil); DBA 04 (oil well blowout; 82.5 bbls. per day); and DBA 05 (rig-vessel collision during well abandonment operations; 1,000 bbls fuel oil). The risk of an accidental oil release is low, however, since only four of the six wells are capable of natural flow (Well Nos. 1-6, 3-6, 5-6, and H-1) and they are currently suspended.

Unocal's_ Execution Plan states that the potential for a well blowout poses the greatest risk of an oil spill during well abandonment operations. Unocal estimates that each well has the potential to release 100 to 800 barrels of oil per day (this is based on an actual production test of an analogous PRC 2879 well). Assuming a 50% water content, this equates to a fluid flow of between 200 and 1,600 barrels per day. Therefore, in the event of a well blowout during abandonment activities, a maximum of 1,600 barrels per day of an oil and water mixture is expected to be released during a free flow condition. Allowing three days to control the well results in a potential oil and water mixture release of 4,800 barrels.

The EIR provides spill trajectories for two spill scenarios for Well No. H-1, which would be the worst case spill location because of its location near to shore: ( 1) an oil well blowout releasing 100 barrels of crude; and (2) a rig-related 1,000 barrel diesel fuel spill. The trajectory model recognized spill duration (i.e., 24 hours etc.) and specific wind and current conditions under three oceanographic seasons (i.e., Davidson, Oceanic, and Upwelling). In general, the oil slick trajectories indicate that the oil would move offshore to the southwest. However, under conditions of onshore winds or currents, sensitive resources at Point Conception would be oiled in less than one hour of a spill. The northern side of the Channel Islands could be impacted depending upon the season and duration of the spill within 98 hours. An oil spill from Well No. H-1 (the furthest well offshore at 13,500') would make landfall in 10 hours.


Texaco: The EIR identifies two DBA that could occur as a result of Texaco's overall project operations: DBA 01 (rig-vessel collision during towing; 1,000 bbls fuel oil); and DBA 05 (rigvessel collision during well abandonment operations; 1,000 bbls fuel oil).

Texaco's Oil Spill Contingency Plan identifies a drill rig/support vessel spill and a well abandonment spill as two potential project-related spills. Texaco defines the worst case spill scenario as a spill of 804 barrels of diesel from the largest support vessel which could collide with the drill rig. The risk of an accidental oil release from a well abandonment spill is low because the producing zone of the well has already been plugged and abandoned. In addition, blowout prevention equipment will be used during the final abandonment process, eliminating any potential for a blowout.

The EIR provided spill trajectories for a spill scenario from Jade East Well No. 1. Under worst case conditions of onshore winds or currents, sensitive onshore resources would be oiled within one hour of a spill. Sensitive resources at Point Conception would be impacted by a spill within 24 hours. The northern side of the Channel Islands could be impacted within 216 hours, depending upon the season and duration of the spill.

Chevron: The EIR identifies four DBA that could occur as a result of Chevron's overall project operations: DBA 01 (rig-vessel collision during towing; 1,000 bbls fuel oil); DBA 02 (anchor-· pipeline rupture; 2,000 bbls); DBA 04 (oil well blowout; 82.5 bbl. crude oil); and DBA 05 (rigvessel collision during well abandonment operations; 1,000 bbls fuel oil).

Chevron's Oil Spill Contingency Plan and Execution Plan identifies an anchor-pipeline rupture of 2,000 barrels of crude oil at well depth as the project's worst case spill scenario. The candidate pipeline in this scenario is the Platform Grace production pipeline that comes ashore at Carpinteria, and passes approximately three miles from the proposed well abandonment site. The only possibility of this pipeline rupture occurring, however, would be in the event of an unlikely navigational error during maneuvering anchor placement. Since the Platform Grace pipeline is outside of the potential impact radius of any of Chevron's wells to be abandoned, this scenario is extremely unlikely.

A loss of well control represents another potential spill scenario. Well Nos. 51 and 53 are capable of natural oil flow, so during well abandonment operations there is a chance that a well blowout could occur. Chevron estimates that if a well blowout occurred during abandonment, no more than a maximum of 13-17 bbl/day of hydrocarbon is expected to be released during a free flow condition. Allowing seven days to control the well results in a potential hydrocarbon release of 119 barrels.

The EIR identifies that under worst case conditions a spill could make landfall from these wells when winds and/or currents were heading toward shore (i.e., winds from the south, current to the north). A spill under these conditions would reach shore around Santa Barbara in 2.3 hours. In spring and summer, prevailing winds and currents would tend to drive the slick to the east, onto


the beaches near Ventura. In the fall and winter a slick would tend to go west and out into the ChanneL It is also possible that within three days a spill could reach the Channel Islands, the nearest points of which are about 25 nautical-miles from Chevron's wells.

4.5.1.2 Oil Spill Prevention

Section 30232 of the Coastal Act first requires the applicant to provide "protection against the spillage of crude oil, gas, petroleum products, or hazardous substances .... " As noted above, the proposed project could result in an accidental oil release. The applicants propose to implement certain measures to minimize the risk of a spill occurring.

The use of a drill rig provides for a primary method of well control. The hydrostatic pressure exerted by the column of drilling mud during well abandonment prevents the undesired flow of formation fluid into the well bore. The State Lands Commission also requires that each drilling well be equipped with a blowout prevention system as a secondary control mechanism to prevent an uncontrolled flow of liquids to the surface. In addition, the current non-producing status of each applicant's wells also minimizes spill risk.

The Commission is requiring in Special Condition 4 that after each applicant completes a preabandonment survey of its respective project area, and prior to the commencement of project activities, they submit to the executive director for approval a Final Anchoring Plan to be implemented during project operations that includes (1) anchoring procedures and locations; and (2) anchor preclusion zones (including but not limited to the location of subsea oil and gas infrastructure (e.g., flowlines)).

The Commission therefore finds the projects, as conditioned, consistent with the first test of Coastal Act section 30232.

4.5.1.3 Oil Spill Response

The second test of section 30232 requires an applicant to provide effective containment and cleanup equipment and procedures for accidental spills that do occur. Despite the precautions proposed by each applicant, the possibility remains that an oil or gas release could occur during project activities. For example, when the Commission approved the removal of Platforms Helen and Herman (CDP No. E-87·6, January 1988), all indications led the Commission to conclude at the time that "the probability of a major oil spill is virtually impossible ... " (e.g., during platform decommissioning, the pipelines were pigged then flushed with seawater for several days). However, during pipeline removal, approximately 40 barrels (1680 gallons) of rust, iron sulfides and suspended tar/oil spilled from these pipelines. Therefore, despite the best prevention measures undertaken by the applicants, the possibility of an accidental hydrocarbon discharge during abandonment activities still exists.

.. CDP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron

Depending on the source or location of a spill, the immediate response team may consist of the standby vessel crew, jack-up rig crew, company personnel onboard the rig, and/or the work boat crew. Containment and cleanup equipment maintained by each applicant on the dedicated standby vessel includes 2,000 feet of boom, an 18 foot boom boat, a Walosep skimmer, absorbent pads and boom, and an oil separator container and transfer pump Expected response time for the standby vessel to reach the rig is approximately ten minutes.

The three applicants are also members of the Clean Seas oil spill cooperative located in Santa Barbara County. Clean Seas has in its inventory over 54,000 feet ofboom including open ocean, offshore, nearshore and protective boom. Clean Seas has three oil spill response vessels (OSRV), Mr. Clean I, Mr. Clean II, and Mr. Clean III, which are usually moored at Port San Luis, Santa Barbara Harbor, and Platform Harvest. Mr. Clean II would be used to respond to nearshore and open-water spills. Major response equipment on-board Mr. Clean II includes l ,500 feet of open ocean boom, 3,000 feet of medium duty boom and two advancing skimmers with 750 gallons per minute pump capacity per unit. Clean Seas also maintains two fast response support boats. If dispatched from Santa Barbara, Mr. Clean II can be onscene at Unocal's wells in 3- 3.5 hours, at Texaco's well in 3 hours, and at Chevron's wells within 30 minutes. The Clean Seas OSRV Mr. Clean III, normally stationed at Platform Harvest (west of Point Conception), can be onscene at Unocal's wells in under 1.5 hours, at Texaco's well in 1 hour and 45 minutes, and at Chevron's wells within 5 hours.

Notwithstanding the extensive oil spill containment and clean-up equipment and services provided by each applicant and Clean Seas, the Commission finds that the second requirement of Coastal Act section 30232, which requires "effective" containment and clean-up equipment for spills that do occur, cannot be met at this time. The Commission interprets the word "effective" to mean that spill containment and recovery equipment must have the ability to keep spilled oil off the coastline. Unfortunately, the state-of-the-art is such that no equipment currently available has the capability to recover all oil from large spills and often even small spills in the open ocean.

Testing results of equipment at government research facilities in the United States and Canada have demonstrated that oil recovery equipment operates with about 50% efficiency in relatively calm waters. These tests and actual experience in the field demonstrate that recovery efficiencies decrease as the dynamics of the sea (turbulence) increases. Clean-up capabilities in the open ocean will continue to deteriorate if sea dynamics increase. All booms and skimmers available for containment and recovery are limited in their effectiveness depending on wave height and wind speed. In wind wave conditions, the containment effectiveness of boom begins to lessen at a wave height of two feet. Under conditions of significant wave heights above six feet, booms and skimmers are largely ineffective (i.e., no measurable amounts of hydrocarbons are recovered). High winds can cause some types of boom to lay over, allowing oil to splash or flow over the boom.

COP Application E-95-12, E-95-13, E-95-14 Applicants: Unoca1, Texaco, and Chevron

In addition to sea dynamics, weather conditions, characteristics of spilled oil, response time, amount of oil spilled, the availabi~ity of equipment and trained personnel all influence the degree to which a response to a spill is successful. Data from the General Accounting Office indicates that although spill response technology has improved in recent years no more than 10-15% of the oil in most major spills _is ever recovered. Shoreline contamination is probable with any major spill in the area. In a much smaller spill, such as the rupture of a pipeline at the El Segundo Marine Terminal in 1991, about 25% of the estimated 660 barrels of spilled oil were recovered in spite of a rapid and large spill response.

Therefore, notwithstanding the on-site spill response equipment provided by each applicant and Clean Seas, the ability to effectively contain and clean-up an oil spill does not exist at this time. The proposed projects are thus inconsistent with the second requirement of Coastal Act section 30232.

4.5.2 Marine Resources


Marine resources shall be maintained, enhanced, and where feasible, restored. Special protection shall be given to areas and species of special biological or economic significance. Uses of the marine environment shall be carried out in a manner that will sustain the biological productivity of coastal waters and that will maintain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and educational purposes.


The biological productivity and the quality of coastal waters, streams, wetlands, estuaries, and lakes appropriate to maintain optimum populations of marine organisms and for the protection of human health shall be maintained and, where feasible, restored through, among other means, minimizing adverse effects of waste water discharges and entrainment, controlling runoff, preventing depletion of ground water supplies and substantial interference with surface water flow, encouraging waste water reclamation, maintaining natural vegetation buffer areas that protect riparian habitats, and minimizing alteration of natural streams.

Adverse impacts to marine water quality and marine resources in the project vicinity may result from each applicant's proposed project.

4.5.2.1 Water Quality Impacts

Routine jack-up rig operations have the potential to adversely impact marine water quality due to the release of contaminants from: ( 1) the overboard discharge or release of ballast/preload water; {2) platform deck drainage {i.e., trace metals, petroleum hydrocarbons, toxic substances and


particulates); (3) water, sanitary and domestic wastes; (4) antifoulants fromyessel hulls; (5) trace metals from sacrificial anodes; ( 6) desalination brine; and (7) fire controi system water. The EIR concludes that although impacts to water quality from these sources are adverse, none of these potential sources of contamination result in persistent levels of pollution or are considered "significant" (i.e., exceed National Pollutant Discharge Elimination System ("NPDES") standards).

The Central Coastal RWQCB has issued General NPDES Permit CAG283001 (Order No. 95-68) for each applicant's project. Each applicant proposes to discharge up to 225,000 gallons per day of treated sanitary wastes, kitchen and laundry graywaters, deck wash down water and desalination brine into the Pacific Ocean. The jack-up rig's treatment system consists of aeration and chlorination of sanitary wastes, and oil/water separation of deck drainage and washdown water. Kitchen, showers and laundry graywaters, brine from the seawater distillation unit, ballast waters and fire control system water require no treatment before discharge. Jack-up rig personnel will conduct daily visual monitoring of deck discharge to ensure that there are no discharges of free oil and grease.

Treated wastewater, graywaters, washdown waters and ballast seawater will be released to the ocean through an 8" outfall pipe running from the deck to six feet below the bottom of the hulL Desalination wastewater brine will be released through a 6" outfall. The discharges from these two outfalls will fall approximately 30 feet to the ocean surface and be substantially diluted by ocean waters very soon after entering the sea. Ballast water discharges and sanitary and domestic wastewater discharges are primarily short-term impacts that are localized and non-persistent in concentration.

To protect the ocean's beneficial uses, the NPDES permit requires the applicant to comply with water quality objectives and discharge requirements specified in the California Ocean Plan. Additionally, the NPDES permit sets effluent limitations in accordance with the federal Clean Water Act. The Ocean Plan limits discharge concentrations for settleable solids, turbidity, pH and acute toxicity while the Clean Water Act limits the discharge of grease and oil, suspended solids and elevation of biochemical oxygen demand due to a discharge. In part, the RWQCB's monitoring program requires each applicant to monitor daily the water flow rate and monitor weekly total coliform organism count, turbidity, suspended and settleable solids, pH, and the concentration of grease and oil.

The State Lands Commission currently prohibits the discharge of drilling fluids, solids, muds, cuttings and untreated water into State waters. Therefore, all toxic wastes associated with subsea well abandonment, such as drilling muds and cuttings, excess mud containing cement, and oily waste associated from platform deck machinery will be transported to shore and disposed of at an approved onshore site.

CDP Application E-95-12, E-95-13, E-95-14 Applicants: Unocal, Texaco, and Chevron Page 2:

The Commission therefore finds the project consistent with CQastal Act section 30231 which requires that "[t]he biological productivity and quality of coastal waters ... shall be maintained ... [through] minimizing adverse effects of wastewater discharges."

4.5.2.2 Hard Substrate

Hard substrate (or "hard bottom") areas are stable rocky substrates that provide habitat for a diverse group of plants and animals to settle, attach and grow. The species composition of hard bottom communities is largely dependent on substrate characteristics (e.g., size, texture and relief), degree of wave and current exposure, as well as light and nutrient availability. The hard bottom, rock substrate attracts a variety and abundance of fishes that far exceed the diversity and numbers of fishes occurring on soft-bottom substrate. In nearshore waters, hard bottom also provides attachment substrate for various kelp species (e.g. Macrocystis pyrifera), typically from the edge of the surfzone to depths of 100 feet. The amount and duration of sediment cover is a major factor influencing the biological diversity of hard bottom habitats. Excessive sedimentation, which can smother benthic organisms, and prevent settlement can reduce species diversity and abundance.

The EIR characterizes the general seafloor conditions in the area ofPRC 2879 (Unocal's wells), PRC 2726 (Texaco's well)·and PRC 1824 (Chevron's wells) as nearly flat and featureless, a soft sediment-covered shelf with scattered, irregular and seasonallow7-to medium-relief hard bottom outcrops (consolidated or semi-consolidated mudstone and siltstone). Geophysical surveys show this region to be characterized by the seasonal and intermittent presence of low- to medium- relief bedrock outcroppings.

Well abandonment activities have the potential to adversely affect existing natural hard bottom biological communities through smothering and crushing of the benthic organisms during: (1) drill rig placement (primarily impact from spud cans located at the base of each leg); (2) placement of drill rig maneuvering anchors during well abandonment; and (3) sedimentation effects resulting from well abandonment and wellhead removal activities.

Hard bottom habitat impacts are not anticipated to occur from Texaco and Chevron's well abandonment activities. Only Unocal's abandonment activities have the potential to adversely affect existing natural hard bottom biological communities. The location of known hard bottom resources in each project area is as follows:

Texaco: In May 1994, Kinnetic Laboratories, Inc. and Continental Shelf Associates conducted a subsea ROV (Remotely Operated Vehicle) survey to identify hard bottom in the vicinity of all of the Subsea Well Abandonment Program wells. The geophysical information for Texaco's well area indicated the presence of significant sediment overburden. It appears there is no hard

7 Storm activities and currents are known to erode and accrete nearshore sediment deposits on a seasonal basis. Low relief hard bottom is seasonally exposed and buried by a thin sediment veneer.

.,


bottom either at the wellhead or within the potential impact radius of the drill rig or its anchor impact area. (Exhibit 5)

Chevron: The 1994 subsea ROY survey documented the presence of large areas of low- to medium-relief rock outcroppings within 335 feet of the wellheads. Chevron's wells are not located on hard bottom so the drill rig spud can placement8 will not result in any hard bottom impacts. A preliminary anchor pattern for the drill rig, however, illustrates that the nearby rock outcrops fall within the southern edge of the anchor pattern. (Exhibit 5)

Unocal: The 1994 subsea ROV survey found intermittent low-relief rock outcroppings, approximately 80 feet to the northwest and southeast of Well Nos. 5-6, 6-6 and 8-6, with widespread continuous low- and medium-relief hard bottom habitat surrounding and underlying Well No. H-1. Well Nos. 1-6 and 3-6 are located in sandy sediments. (Exibit 5)

At Well No.'s 5-6,6-6, and 8-6, hard bottom could potentially be impacted by spud can placement, but according to the EIR, Unocal can anchor the rig such that all hard bottom can be avoided and protected (Exhibit 5). At Well No. H-1, the wellhead is located on and surrounded by hard bottom habitat, and impacts from the three spud cans are unavoidable. Unocal's project may impact 4,986 square feet of hard bottom. (Exhibit 5).

The Commission is requiring in Special Condition 3 that prior to the start of the projects, the applicants each contract with a qualified consultant to conduct a pre-abandonment survey within their respective project impact zones to identify in part the location, areal extent and physical characterization (i.e., high- or low-relief, sand-covered, etc.) of hard bottom. In Special Condition 4 the Commission is requiring the applicants to submit to the executive director for approval a Final Anchoring Plan to be implemented during all offshore project activities that includes (1) anchoring procedures and locations; and (2) anchor preclusion zones (i.e., areas where the pre-abandonment survey identifies the presence of hard bottom, kelp and subsea oil and gas infrastructure (e.g., flowlines)).

In Special Condition 5 the Commission is requiring that within 30 days of project completion, each applicant's consultant conduct a post-abandonment survey to identify in conjunction with the results of the pre-abandonment survey the location and quantify the extent (i.e., the number of square feet) of any disturbance to hard bottom areas that could not be avoided during project operations. Within 45 days of the completing the post-abandonment survey, each applicant's consultant is to submit directly to the executive director a written report describing the results of the post-abandonment survey along with an analysis of the pre-and post-abandonment survey results to derive net project impacts to hard bottom.

R The representative rig, the Glomar Adriatic VIII, has three legs including one bow and two stern spud cans at each leg base. Crushing of hard bottom areas can result from the spud cans. Each spud can covers approximately 46 feet in diameter, and during a single placement of the rig over a well, 4,986 square feet can be impacted by the three legs.


If a comparison of the pre- and post-abandonment surveys shows that impacts to hard bottom have occurred, the Commission is requiring in Special Condition 6 that each applicant compensate for all project-related adverse impacts to hard bottom through payment of a compensatory hard bottom mitigation fee to the United Anglers of Southern California (UASC). The fee is to be used to construct a new artificial reef or augment an existing artificial reef in State waters within the Southern California Bight.

Special Condition 6 requires that the amount of the compensatory hard bottom mitigation fee be calculated by multiplying the total square footage of adversely affected hard bottom (as determined by comparing the pre- and post-abandonment surveys) by a compensation rate of $6.57. The compensation rate is based on the overall cost to build a new artificial reef, or augment an existing artificial reef in State waters within the Southern California Bight. The overall cost is based on the following information:

Compensatory Hard Bottom Mitigation Fee

1 Construction of Hard bottom Habitat $4.60 Assumptions: (1995 dollars) a) Estimate based on actual • Cost of Materials (i.e. quarry rock) construction costs for artificial • Transport reefs in the Southern California • Deposition Bight area. • Insurance b) Cost== $200,000/acre. (43,560

sf /1 acre)

2 Project Administration for $0.46 Overhead to UASC not to exceed UASC 10% of total funds collected.

SUBTOTAL $5.06

3 Project Contingency $1.51 Contingency of 30% for unanticipated project-related changes in cost of design/planning/permitting, materials, labor, or transportation .

··· ..... .. ··. TOTAL $6.57 .··

The fee is to be paid by the applicant to the UASC within 30 calendar days of the executive director's review and written determination of the results of the pre- and post-abandonment surveys.

The construction of a new artificial reef, or augmentation of an existing reef, is to be carried out pursuant to a Memorandum of Agreement (MOA) by and between the Coastal Commission, the California Department ofFish and Game (CDFG) and the United Anglers of Southern California (UASC) (Exhibit 6). If any impacts to hard bottom have occurred, the CDFG has agreed to


prepare a plan to be approved by the Commission's executive director to spend the monies in the hard bottom mitigation fund on either the construction of a new artificial reef, or augmentation of an existing artificial reef in State waters within the Southern California Bight.

The CDFG administers the California Artificial Reef Program in part for the purposes of ( 1) placing artificial reefs in state waters and (2) determining the requirements for reef siting and placement. The CDFG has agreed to assume the lead responsibility for the planning, siting, design and permit requirements for the construction of any new artificial reef or augmentation of an existing artificial reef using any fees paid by the applicants (Exhibit 7). The UASC, a volunteer group of recreational anglers interested in preserving, protecting and enhancing marine resources and fishing opportunities, has agreed to receive any hard bottom mitigation fee paid by the applicants.

According to the terms of the MOA, the UASC is to deposit all funds in an interest-bearing account within 30 days of receipt of any fee. These funds including all earned interest shall be expended by the UASC solely for reef materials, construction costs, and the UASC's administration of the fund (not to exceed 10% of the total collected fees). The CDFG will absorb

. any costs associated with the planning, siting, design and permit requirements to construct a new artificial reef or augment an existing reef.

The MOA further requires:

• Within 180 days of the date on which all fees have been paid to the UASC the CDFG shall develop and submit for review and approval,-by the Commission's executive director, a plan to spend the monies within the fund on either the construction of a new artificial reef or augmentation of existing artificial reef within the Southern California Bight;

• Within one year of the Commission's executive director approval of a plan to spend the compensatory hard bottom mitigation fund, the CDFG is to secure all necessary government approvals to construct a new artificial reef or augment an existing artificial reef;

• Within 90 days of either: ( 1) the granting of all necessary governmental approvals, or (2) approval by the Commission's executive director of a plan to spend the monies in the fund, whichever occurs later, the UASC is to secure and enter into a construction contract with a contractor to construct either a new artificial reef or augment an existing artificial reef; and

• Within two years of approval by the Commission's executive director of a plan to spend the monies in the fund, the UASC is to spend these monies to complete the construction of either a new artificial reef or augmentation of an existing artificial reef.

The Commission therefore finds that the applicants' efforts to avoid hard bottom in the project areas, where feasible, in combination with payment of a compensatory hard bottom mitigation


fee (for the purpose of creating a new artificial reef or augmenting of an existing artificial reef) if hard bottom is impacted during project operations (Special Condition 6), is consistent with Coastal Act section 30230 which requires that "[m]arine resources shall be maintained, enhanced, and where feasible, restored."

4.5.2.3 Kelp

Extensive nearshore kelp beds line the Southern California Bight, providing habitat and food for a variety of invertebrates and fishes. No kelp resources, however, have been identified by the EIR in the vicinity of either Unocal (Well Nos. 1-6, 3-6, 5-6, 6-6, 8-6, and H-1), Texaco (Jade East Well No. 1) or Chevron's (Well Nos. 51, 52, and 53) wells. With the exception of Well No. 1-6, five ofUnocal's wellheads are located in water depths of 185 to 275 feet which exceed the normal depth ranges for kelp growth. The closest kelp beds to Unocal's Well No. 1-6 are the western edge of Kelp Bed No. 32 (located one mile to the east) and the southern edge of Kelp Bed No. 33 (one mile northwest of Point Conception). Texaco's well is located in 140 to 150 feet of water which exceeds the normal depth ranges for kelp growth. Chevron's wells are located in water 65 feet deep, but the nearest kelp beds are located about .5 miles to the west and 1. 7 5 miles to the west (Kelp Bed No. 21).

The applicants have proposed to minimize any disturbance to kelp by using identified vessel traffic corridors as specified in the Santa Barbara/Channel/Santa Maria Basin Oil Service Vessel Traffic Corridor Program. The Commission is requiring in Special Condition 3 that each applicant conduct a pre-abandonment survey in part to quantify any kelp that may be in the project area. The Commission is also requiring in Special Condition 4 that after each applicant completes a pre-abandonment survey and before commencement of project activities, it prepare and implement a Final An~horing Plan during all offshore project operations that includes: (1) anchoring procedures and locations; and (2) anchor preclusion zones (i.e., areas where the preabandonment survey identifies the presence of hard bottom, kelp and subsea oil and gas infrastructure (i.e., flowlines). In Special Condition 5, the Commission is requiring each applicant to complete a post-abandonment survey that locates and quantifies any damage to kelp plants caused by project activities.

If the results of the pre- and post-abandonment surveys show that project activities caused statistically significant damage to kelp plants, the applicant is required in Special Condition 7 to develop a Kelp Restoration Plan and submit it to the Commission in the form of an amendment to this permit.

The Commission therefore fmds that each proposed project, in combination with Special Conditions 3, 4, 5 and 7, is consistent with Coastal Act section 30231 which requires that "[ u ]ses of the marine environment ... be carried out in a manner ... that will maintain healthy populations of all species of marine organisms."


4.5.2.4 Fish

Wellhead removal will likely result in a localized loss of structure-associated fish and epifaunal invertebrates. When the wellheads are removed, the attached invertebrates will also be removed from the system and many of the adult and sub-adult fishes associated with these structures are expected to scatter to adjacent hard bottom. The EIR found that most of the wellheads slated for abandonment are located in areas of intermittent low- to medium-relief naturally-occurring hard bottom outcroppings. The extent of hard bottom in the immediate environs (i.e., within anchoring radius) based on ROV survey observations ranged from 5 to 80% (mean: 35.6%). The EIR found that while the fish will not be able to aggregate around the wellheads as they presently do, individuals will not necessarily be lost from the system. The EIR states that the naturallyoccurring rock outcrops of varying relief in close proximity to the wellheads will provide alternative habitat for many of the displaced fishes.

In commenting on the Draft EIR, the Central Coast Hook & Line Fishermen's Association stated that if the wellheads were to be removed, the fishery stock would be depleted. The Association maintains that the hard wellhead structures serve to produce fish biomass rather than simply act as aggregation sites for adults and sub-adults. The Association suggests that the presence of the wellhead structures results in increased productivity of the fish species aggregating on the structures, and that over time, this increased productivity results in more fish in the surrounding areas.

The ability of artificial structures to actually enhance fish productivity is not clear. In a comprehensive study comparing the fish assemblages on artificial and natural reefs along-the Southern California coast, Ambrose and Swarbrick (1989) concluded:

[t]he ability of artificial reefs to attract fish, and hence increase fishing success, is well established, but the extent to which the reefs actually produce fish (i.e., cause an overall increase in fish biomass) is not clear.... It is generally acknowledged that the high density of fish on new artificial reefs is due primarily to aggregation; the implication is that older reefs, with more mature biota, have produced the high densities of fish.... However, high densities of fish on older reefs could also be due in large part to aggregation... Therefore, the presence of high densities offish, even on reefs that have abundant resources, does not guarantee that the reef has increased the productivity, nor that all of the fish on the reef were produced on the reef ·

Thus, while there is good evidence to show that large aggregations of fish do occur at the wellheads, the scientific evidence available at this time does not demonstrate that all artificial structures actually enhance fish productivity. (The attraction factor of artificial reefs could actually make adult fish more vulnerable to overfishing.) Thus, one of the most probable effects of removing the wellheads would be the loss of vertical structures that serve as aggregation sites for adult and sub-adult fish. In this respect, the EIR concludes that removal of the wellheads will have an adverse but insignificant effect (Class Ill).


The Commission therefore believes that removal of the wellhead structures will not cause . significant long-term impacts to the biological productivity of the marine environment. The Commission finds the project consistent with Coastal Act section 30230 which requires that "[u]ses of the marine environment ... be carried out in a manner that will sustain the biological productivity of the coastal waters .... "

4.5.2.5 Marine Mammals

Marine mammals in the project areas that could be affected by the proposed project include cetaceans (California Gray Whale), pinnipeds (Harbor Seals and Sea Lions), and one fissiped species (Southern Sea Otter). Federally listed endangered marine mammals which are found in the project areas (in decreasing order of abundance) include the Humpback Whale (Megaptera novaeangliae), Blue Whale (Balaenoptera musculus), Fin Whale "(B. musculus), and Right Whale (Balaena glacialis). The Southern Sea Otter (Enhydra lutris nereis) is a threatened species and may be present in nearshore waters at the western end of the Santa Barbara Channel (e.g., Coho Bay anchorage), which is outside of the immediate project area. Sea otters are rare in this area and tend to stay close to shore, in and amongst the kelp.

The California Gray Whale (Eschrichtium robustus), which was recently delisted (June 1994) from the federal list of endangered species, is the most common whale in the Santa Barbara Channel area. The EIR estimates their population to be about 17,000 animals. Their annual migration pattern through the Santa Barbara Channel includes southbound migration from December through February (with a peak in January), and a northbound migration as adults and sub-adults pass through the area in February and March, followed by mother and calf pairs in March and April.

Impacts to marine mammals due to wellhead abandonment and flowline abandonment/removal activities include: (1) noise from the drillrig or support vessels and helicopter traffic which could affect acoustic communication and/or echolocation signals; (2) increased risk of collision between a vessel and a marine mammal; and (3) increased water turbidity that could affect foraging behavior as a result of domestic discharges. Noise and water turbidity impacts, however, will be short-term and localized in nature, which may result in an initial change in a marine mammals' behavior, but which should result in no lasting impacts to animals. The EIR states that cetacean studies indicate that noises associated with oil and gas activities, at worst, result in a "startle" response.

The primary hazard facing marine mammals is injury or death from collision with vessels, the drill rig, lengths of floating pipeline, or anchor or work cables. Should a collision occur resulting in serious injury or death, it would be considered a significant impact due to the marine mammals protected status. According to National Marine Fisheries Service stranding and accident statistics, one to two collisions and as many as four incidents between vessels and resident marine mammals occurs every year in the Southern California Bight. The EIR identifies the California Gray Whale as swimming closer to shore than other cetaceans, and therefore, it may be


at a slightly higher risk of collision from project activities. Overall, the increased risk of marine mammal collision with increased numbers of project-related vessels is considered "very low"(See also NMFS Biological Opinion, 1984, cited in CDP No. E-93-12). Also, the temporary nature of the work will reduce the potential for impact to marine mammals.

The EIR identifies several Pacific Harbor Seal (Phoca vitulina) haul out sites around Point Conception in the vicinity ofUnocal's and Texaco's wells, and in the vicinity of Summerland near Chevron's wells as follows:

Unocal: There are four separate identified Pacific Harbor Seal (Phoca vitulina) haul out sites noted around Point Conception: (1) Site 11- just east of Point Conception; (2) Site 11.1-Lighthouse/Big Cove; (3) Site 11.2- Lighthouse Reef; and (4) Site 10.8- Government Point. The EIR identified that Sites 11 and 11.1 have the highest observed abundances of harbor seals. Prior to 1990, Site 11 had census counts that ranged from 223 to 554 seals and was a historic rookery. In recent years, Site 11.1 has had harbor seal abundances of 197 to 451 seals. Well No. 1-6 is closest to these haul out sites, lying within .4 to .5 miles from sites 11.0, 11.1, and 11.2. However, the rest ofthe wells lie 4,500 feet or more offshore. Since Unocal's project does not include onshore removal work activities, no direct impacts to the haul out sites are expected.

Texaco: The Jade East Well No. 1 is 6 miles east from sites 11.0, 11.1, and 11.2, and lies approximately 7,100 feet or more offshore. Due to the distance of Texaco's project from the haul out sites at Point Conception, and because there is no onshore removal work activities, no direct impacts to the haul out sites are expected.

Chevron: There are four Pacific Harbor Seal haul out areas identified within 3 to 4.5 miles of the wells. These haul-out sites are identified as: Site 5.0 (Carpinteria, 0.1 km. west of the Chevron pier); Site 6.0 (Carpinteria, 0.3 km. west of the Chevron pier); Site 7.0 (Carpinteria State Beach); and Site 8.0 (Sand Point). The most prominent of these sites is Site 5.0, where recent surveys conducted between 1990 and 1992 identified a total of 127 to 137 individuals. There is no onshore work associated with Chevron's project, so no direct impacts to haul out sites are expected.

The increased level of offshore activity at both Unocal and Chevron's wells, however, may disturb marine mammal migration patterns or the feeding and foraging patterns near seal and sea lion haul-out areas. These populations may be vulnerable, especially during peak breeding season, when there are large numbers of animals in the area. However, due to the short duration of project activities at each well site, impacts to the seal haul out sites will not be significant.

Each of the applicants has completed a Marine Mammal Wildlife Contingency Plan to be distributed prior to commencement of project operations to all vessel operators. The plans (1) identify the marine mammals that may be observed in the project area, including species present and their migration and/or behavioral patterns; (2) advise vessel operators of marine mammal avoidance strategies; (3) establish response procedures for a vessel operator to follow if the


vessel collides with a marine mammal; and (4) include the names and phone numbers of persons within the responsible government agencies and local marine mammal care and rehabilitation centers who should be contacted in the event that a vessel collides with a marine mammal.

The Commission therefore finds that each applicant's project will be carried out in a manner consistent with Coastal Act section 30231 which requires that "[ u ]ses of the marine environment ... be carried out in a manner ... that will maintain healthy populations of species of marine

. " orgamsms.

4.5.2.6 Conclusion

The applicants have incorporated a number of mitigations into their proposed projects that, in combination with Special Conditions 3, 4, 5, 6 and 7 of this permit, will reduce potential impacts to marine water quality and marine resources during project operations. The Commission therefore finds each project consistent with Coastal Act sections 30230 and 30231.

4.5.3 Commercial and Recreational Fishing

Coastal Act section 30234.5 states:

The economic, commercial, and recreational importance of fishing activities shall be recognized and protected.

Commercial fishing opportunities in the Santa Barbara Channel include sea urchin, Pacific bonito, rock crab, Pacific mackerel, Pacific sardine, yellowfin tuna, skipjack tuna, and red rockfish. Principal fishing gear employed in the region include purse seine, trawl, trap, diving and hook and line. Santa Barbara Channel regional landings data reflect a multi-species fishery consisting of invertebrates and finfish with an average annual dockside or ex-vessel value exceeding 24 million dollars. The 23 well sites in the overall Subsea Well Abandonment Program are found within California Department ofFish and Game ("CDFG") Blocks 657, 656, 655, 654 and 652, encompassing the area from Pt. Conception to Ventura. These blocks consist of 10 minute latitude by 10 minute longitude cells used to track fish catches from California coastal and offshore waters. The primary species caught across all blocks from 1988 to 1992 were sea urchin, Pacific bonito, rock crab, Pacific mackerel, Pacific sardine, red rockfish, sea cucumber and California halibut.

An average of 1.1 million southern California residents participated in recreational fishing from 1987 to 1989, making 4.9 million marine recreational fishing trips during this period. Commercial passenger for hire fishing vessels (CPFVs or "party boats") represent a valuable component of the tourism industry of the Santa Barbara Channel communities. The CDFG collect data on "party boat" catches (i.e., numbers offish) and effort (i.e., angler hours) from the fisheries blocks. These data show that rockfishes, kelp bass, Pacific mackarel, halfmoon and barred sand

---~~~-~------------------~----~-


bass ac~ounted for most of the sportfishing catch during 1988-1992. However, as a group, the rockfishes were more frequently caught by anglers.

The proposed projects could result in the following economic impacts to commercial fishermen and sportfishing groups: ( 1) jack-up rig placement will temporarily preclude fishing in the immediate area surrounding the rig; and (2) removal of the wellheads will result in a reduction of artificial structures at which certain commercial and recreational fishing occurs.

4.5.3.2 Fishery Preclusion Areas

Fishing will be temporarily precluded in the project areas during abandonment activities. To minimize any potential adverse impacts to fishing operations near the project sites, the SLC is requiring: ( 1) the drilling rig and support vessels to operate in compliance with all established vessel traffic corridors and oil service support corridors while present in the Santa Barbara , Channel; (2) notification of local fishermen concerning the proposed activities via the Joint Oil/Fisheries Committee notification procedures; and (3) issuance of a Notice to Mariners at the commencement of the well abandonment program to advise commercial and sport fishermen and other commercial traffic about scheduled project activities. The notice will be posted at all embarkation points for fishery operations in the Santa Barbara Channel area.

Unocal, Texaco, Chevron and the other well operators have agreed also to pay compensation to hook and line fishermen for documented loss of catch associated with areal preclusion caused during rig operations at the well locations (personal communication with Ed Morton, Morton Associates, Inc., February 27, 1996). Such compensation will be negotiated in accordance with procedures contained in the Joint Oil Fisheries Liaison Office's Guidelines Intended to Reduce Conflicts Between Geophysical Surveys and Fishing Operations (personal communication with Craig Fusaro, Joint Oil Fisheries Liaison Officer, February 26, 1996 and Ed Morton, Morton Associates, Inc., February 27, 1996).

4.5.3.3 Wellhead Removal

The Commission also recognizes that removal of the wellheads will result in a reduction of artificial structures at which certain commercial and recreational fishing occurs. The Central Coast Hook & Line Fishermen's Association maintains that removal of the wellheads could result in a loss of20% ofhook and line fishermen's annual income (letter (undated) from Phil Schenck, Central Coast Hook & Line Fishermen's Association, to the Coastal Commission (received February 20, 1996))(Exhibit 4).

The Association has requested that the wellhead structures be left intact and abandoned-in-place after the well holes have been permanently sealed. The Commission has examined the alternative of leaving the wellhead structures in place but has found that this project alternative is not feasible. (See the discussion of "Project Alternatives" in section 4. 3 of these findings.)


The Association further argues that if the wellhead structures cannot be left on the seafloor, the State and/or the well operators should build new deep water artificial reefs {> 100 foot depth) to replace the wellheads. According to the CDFG it would cost between $100,000- $200,000 to build 8-10 small deep water reefs with quarry rock (each about 1-1.5 meters high). There are currently no public funds available to design and build such deep water artificial reefs.

The Coastal Act does not require Unocal, Texaco, Chevron and the other well operators to provide mitigation for economic impacts to commercial and recreational fishermen due to the removal of wellheads placed on the seafloor for the sole and exclusive purpose of oil and gas production, not fisheries enhancement. The commercial fishermen and sportfishing groups that successfully fish at these wellhead sites have over the years derived an incidental economic benefit from the placement of these hard vertical structures on the seafloor. Furthermore, the well operators' SLC oil and gas lease provisions are expressly clear that these wellheads and other associated oil and gas structures are to be removed upon termination or relinquishment of the leases. The leases explicitly require the lessees, at the request of the State, to remove all "platforms, fixed or floating structures" and "restore the premises" upon the expiration or termination of the lease. (See, for example, SLC Oil and Gas Lease PRC 2879.1, section 14, issued to Unocal in April 1962.) Thus, the fishermen could not reasonably expect that these wellhead structures would remain on the seafloor in perpetuity. The Commission therefore finds that requiring mitigation for economic impacts suffered by commercial hook and line fishermen and sportfishing groups is not warranted.

The Commission thus finds that each project is consistent with Coastal Act section 30234.5 since the "economic'~ and "commercial" importance of fishing activities will be protected.

4.5.4 Air Quality

Coastal Act section 30253(3) states:

New development shall be consistent with requirements imposed by an air pollution control district or the State Air Resources Control Board as to each particular development.

The applicants' projects will result in air emission releases from the jack-up rig, work boat and tug assist vessel engines. Unocal's project emissions are estimated to be 19 tons nitrogen oxides (Nox)• 6.7 tons carbon monoxide (CO), 1.6 tons reactive organic compounds (ROC), 0.5 ton sulfur dioxide (S02), and 2.9 tons particulates (PM10). Texaco's project emissions are estimated to be 3.3 tons nitrogen oxides (Nox)• 1.2 tons carbon monoxide (CO), 0.3 tons reactive organic compounds (ROC), 0.1 ton sulfur dioxide (S02), and 0.5 tons particulates (PM10)· Chevron's project emissions are estimated to be 9.2 tons nitrogen oxides (Nox)• 3.3 tons carbon monoxide


(CO), 0.7 tons reactive organic compounds (ROC), 0.3 ton sulfur dioxide (S02l and (5) 1.5 tons

particulates (PM1o)· 9

The Santa Barbara County Air Pollution Control District ("APCD") is the local air pollution control district responsible for implementing federal and state air quality standards in the project areas. APCD Rule 202.C.2.g exempts from permit requirements piston type internal combustion engines on work-over rigs when the engines are used for the repair, work-over, maintenance or abandonment of wells. The engines on the jack-up rig and support vessels qualify for this exemption. Consequently, on November 3, 1995, the APCD determined that Unocal and Chevron's projects were exempt from APCD permit requirements (Exhibit 8). (Texaco has not applied for an exemption from the APCD, although they are party to the "Emission Reduction Agreement. ")

However, in a November 13, 1995 letter to Coastal Commission staff, the APCD stated that notwithstanding its exemption from current APCD new source rules and regulationsw, the overall Subsea Well Abandonment Program will generate significant Class I air impacts that, if not properly mitigated, will be inconsistent with Santa Barbara County's adopted 1994 Clean Air Plan (Exhibit 9). The APCD estimates that the Subsea Well Abandonment Program will emit a total of90 tons ofNox, a precursor to ozone. Santa Barbara County is currently a designated non-attainment area for both the federal and state ozone standards. The APCD states that if the program were not exempt fro~ APCD current rules and regulations, the emission totals would trigger APCD requirements for Best Available Control Technology, formal air quality impact analysis, and offsets.

In response to tlie concerns raised by the APCD, Unocal, Texaco, Chevron and the other well operators have agreed to an "Emission Reduction Agreement" that includes providing the APCD with $748,750 (of this total, Unocal is to pay $163,155; Texaco is to pay $29,985; and Chevron is to pay $240,764 11

) that will be used to fund programs (such as the retrofitting of trawling vessel engines) to help mitigate the short-term air quality impacts of the Subsea Well Abandonment Program (Exhibit 1 0).

Unocal (March 18, 1996), Texaco (March 18, 1996), and Chevron (20, 1996) have amended their project descriptions to include the terms of the "Emission Reduction Agreement" as follows (Exhibit 11 ):

9 Emission totals for each applicant's project is based on emission totals (average power consumption rates) for the jackup rig Glomar Adriatic VIII and specific support vessels. In the event a different drilling rig or support vessels are selected , emission inventories will be recalculated by the APCD.

10 APCD Rule 202 is currently undergoing potentially significant revisions which may change the requirements and exemptions of Rule 202.C.

11 Chevron's share of the Emission Reduction Agreement also includes well abandonment and flowline removaVabandonment activities on PRC 2894 and PRC 2199.


• Each operator shall pay (Unocal $163,155, Texaco $29,985, and Ch~vron $240,764) to the APCD for programs to help mitigate each of their proportional share of the short-term air emissions associated with the Subsea Well Abandonment Program. A total payment of $748,750 will satisfy the air quality mitigation obligation for the entire Subsea Well Abandonment Program and the resulting long-term emission reductions will belong to the APCD and will be used to provide a long-term clean air benefit;

• The pre-survey work and the subsea well abandonment portion of the program is anticipated to be completed within a 12 consecutive month period. Flowline abandonment/removal operations shall occur in a 12 consecutive month period separate from the subsea well abandonment portion of the program;

• The operators shall employ a single rig using Caterpillar 399 T A SCAC or other engines with equivalent or lower emissions than those described in the EIR. The operator shall comply with all project descriptions and assumptions used to prepare the air emissions estimates within the EIR and with the mitigation agreement;

• The operators will put forth a good faith effort to provide a workboat or crewboat to APCD for the purpose of demonstrating effectiveness of lean bum catalyst;

• A deposit of.1 0% shall be paid to the APCD within 30 calendar days after all operators receive their coastal development permits. Final payment to the APCD will be paid no later than 30 days after all operators execute a binding rig contract. Operators shall not mobilize the rig to the first wellsite until 120 days after the date of APCD's receipt of the entire

"payment of $748,750 from the operators;

• The APCD shall return the deposit 30 days from the date that the operators surrender their coastal development permits if the program is not going to proceed; and

• The operators shall request that all the above conditions be incorporated into the SLC Mitigation Monitoring Plan (for the Subsea Well Abandonment Program).

Since the proposed projects are consistent with Santa Barbara County APCD rules and requirements, the Commission finds the project consistent with Coastal Act section 30253(3).

4.5.5 Public Access/Recreation


Development shall not interfere with the public's right of access to the sea where acquired through use or legislative authorization, including, but not limited to, the use of dry sand and rocky coastal beaches to the first line of terrestrial vegetation.



Coastal areas suited for water-oriented recreational activities that cannot readily be provided at inland water areas shall be protected for such uses.

Well abandonment activities at each project area will not significantly impact recreational users or restrict public access. All work will be conducted offshore using the drill rig and support vessels (no onshore work is associated with these projects). Any potential impacts to recreational boaters in the project areas will be temporary. The Commission therefore finds the proposed project consistent with Coastal Act sections 30211 and 30220.

4.5.6 Cultural Resources


Where development would adversely impact archaeological or paleotological resources as identified by the State Historic Preservation Officer, reasonable mitigatiOf! measures shall be required.

Cultural resources consist of places or objects important to cultures, communities and individuals for scientific, historical and religious reasons. Cultural resources include archaeological sites and remains, shipwrecks, artifacts and places of importance that provide evidence of past human activities. Cultural resources identified in the vicinity of each project area are discussed below:

Unocal: The EIR identifies 21 shipwrecks (of these shipwrecks, only BLM 286 is listed as significant) and four underwater prehistoric sites within or near the offsh9re area of PRC 2879. None of these documented cultural resources occur within the project impact area (i.e. well site disturbance radii) for the six wellheads.

Texaco: The EIR states that two previous cultural resources investigations have been conducted for PRC 2726 (Macfarlane, in CSA Inc., 1986; Hughston, in Pelagos Corporation, 1985). Two shipwrecks (of these shipwrecks, only BLM 736 is listed as significant) and one underwater prehistoric site have been identified within or near to the offshore area ofPRC 2726. None of these documented cultural resources occur within the project impact area (i.e. well site disturbance radii).

Chevron: The EIR identifies three shipwrecks within the offshore area ofPRC 1824, and only one has been documented as moderately significant (the Chetco (BLM 067)). Two previous cultural resources investigations were reviewed for PRC 1824 (Macfarlane, in McClelland Engineers, Inc., 1983; Hunter, in Continental Shelf Associates, 1984), and no cultural resources were identified near the wells to be abandoned. There were also no underwater prehistoric sites identified in PRC 1824. None of the documented cultural resources occur within the project impact area (i.e. well site disturbance radii), however.


Since project activities will not cause impacts to cultural resources, the Commission finds each project consistent with Coastal Act section 30244.

4.5. 7 Visual Resources

Coastal Act section 30251 states in part:

The scenic and visual qualities of coastal areas shall be considered and protected as a resource of public importance. Permitted development shall be sited and designed to protect views to and along the ocean and scenic coastal areas, to minimize the alteration of natural land forms, to be visually compatible with the surrounding areas, and, where feasible, to restore and enhance visual quality in visually degraded areas ....

In general, the views from shore of the Santa Barbara Channel presently include a scattering of approximately 1 7 oil and gas platforms, with Platform Heritage located offshore southeast of PRC 2879 (Unocal) and PRC 2726 (Texaco), and Platforms Hilda and Hazel located near the well abandonment activities at PRC 1824 (Chevron).

Unocal: The affected viewshed for the abandonment and removal activities on PRC 2879 extends from Cojo Bay, north past Point Conception, and south to San Augustine. The onshore area is a primarily rural landscape with scattered industrial facilities (e.g., UnocaVCojo Bay and Point Conception). The viewing population is estimated to be less than 500 individuals including: employees of the Bixby Ranch, residents of Hollister Ranch, travellers along the Southern Pacific Railroad (150 passengers per day would view the project for up to one minute), and surfers that

· have gained access to Bixby or Hollister Ranch by boat. Recreational users of Gaviota State Park may have distant views of the project from approximately 12 miles away.

Texaco: The affected viewshed for the well abandonment activities on PRC 2726 extends from 2.5 miles east of Point Conception, westward to within two miles of Gaviota State Park. Almost all of this coastline lies within the Hollister Ranch. The onshore area is a primarily rural landscape with scattered residential. The viewing population is estimated to be less than 500 individuals including residents of Hollister Ranch and travellers along the Southern Pacific Railroad (150 passengers per day would view the project for up to three minutes). Recreational users of Gaviota State Park may have distant views of the project from approximately six miles away.

Chevron: The affected viewshed for the abandonment and removal activities on PRC 1824 extends from Carpinteria State Beach to East Beach in Santa Barbara. Most of the area between Montecito and Carpinteria is rural (agriculture), except for the city of Summerland. Carpinteria State Beach, Loon Point Beach, Lookout County Park, East Beach and the approximately 250 residences in the vicinity ofPRC 1824 would be the primary view receptor areas. The offshore project work area is visible from the primary view corridors of U.S. Highway 101, which has been designated in the Santa Barbara County Coastal Plan as a View Corridor. The viewing


population could number up to 68,000 people daily, including approximately 500 residents, 1,534 recreational park users and 66,000 travelers along the U.S. Highway 101 corridor.

During all phases of the offshore abandonment work activities (including movement, anchoring and operations), the drill rig and support vessels will be working within 1.5 to 3.0 miles of shore. The size and structure of the drill rig and the movements of the support vessels will be highly visible to recreational users, travelers and residents within the visual impact area. Drill rig nighttime light impacts to residents in the vicinity will be mitigated through use of light shields on the rig. However, since project activities are short-term (51 days to remove Unocal's five wells, 30 days to remove Chevron's three wells, and nine days to remove Texaco's one well), any adverse visual impacts will be temporary.

The Commission therefore finds the proposed projects consistent with Coastal Act section 30251 which requires that the "scenic and visual qualities of coastal areas ... be protected."

4.5.8 Section 30260 Coastal-Dependent Industrial "Overrride" Provision ·

Section 30101 of the Coastal Act defines a coastal-dependent development or use as that which "requires a site on or adjacent to the sea to be able to function at all." Ports, commercial fishing facilities, offshore oil and gas developments (e.g. subsea wells and associated pipelines) are examples of development considered "coastal dependent" under section 30 10 l.

In section 30260, the Coastal .t\ct further provides for special approval consideration of coastaldependent industrial facilities that are otherwise found inconsistent with the resource protection and use policies contained in Chapter 3 of the Coastal Act. Coastal-dependent industrial facilities must first be tested under all applicable policies in Chapter 3. If the proposed projects do not meet one or more of these policies, the developments can then be analyzed under the three requirements of section 30260 of the Coastal Act which specifically states:

Coastal-dependent industrial facilities shall be encouraged to locate or expand within existing sites and shall be permitted reasonable long-term growth where consistent with this division. However, where new or expanded coastal-dependent industrial facilities cannot feasibly be accommodated consistent with other policies of this division, they may nonetheless be permitted in accordance with this section and section 30261 and 30262 if (1) alternative locations are infeasible or more environmentally damaging; (2) to do otherwise would adversely affect the public welfare; and (3) adverse environmental affects are mitigated to the maximum extent feasible.

As described in section 4.5.1 of this report, the proposed projects do not meet the standards of section 30232 due to the potential for, and significant impacts caused by a marine oil or gas spill. Since each of the projects qualify as a "coastal-dependent industrial facility" the Commission may nevertheless approve the project if the three requirements of section 30260 can be met.


4.5.8.1 Alternative Locations

The Coastal Commission may approve each proposed development if notwithstanding the projects inconsistency with one or more policies of Chapter 3 it finds that alternative project locations are infeasible or more environmentally damaging. Since the proposed projects involve abandonment and removal of existing facilities, the issue of whether the projects are sited in the least environmentally damaging location is not applicable. Therefore, each proposed project is consistent with the first test of section 30260.

4.5.8.2 Public Welfare

The second test of Coastal Act section 30260 states that non-conforming coastal-dependent industrial development may be permitted if "to do otherwise would adversely affect the public welfare." The test requires more than a finding that, on balance, a project as proposed is in the interest of the public. It requires that the Coastal Commission find that there would be a detriment to the public welfare were the Coastal Commission to deny a permit for the project proposal.

The proposed projects involve the permanent abandonment of existing, shut-in subsea wells as required by State Lands Commission oil and gas lease provisions. Improperly abandoned wells could potentially cause a hydrocarbon release into marine waters. Thus, denial of the projects may be detrimental to the public's welfare.

However, in addition to determining whether a refusal to allow the projects to be carried out at all would adversely affect the public welfare (which the Commission has answered in the affirmative), the Commission must also determine whether a refusal to allow the projects to be carried out precisely in the manner proposed by the applicant would adversely affect the public interest.

In previous sections of these fmdings, the Commission has identified and outlined the valuable public policy goals that will be furthered by imposing additional mitigation measures. The question thus becomes whether the conditions of this permit which impose additional mitigation upon the applicants will have an adverse effect on the public interest. The applicants have made no showing that such requirements are financially or otherwise infeasible. Therefore, the Commission finds that the proposed projects, as conditioned by this permit, will not have an adverse effect on the public welfare. The proposed projects are therefore consistent with the second test of section 30260.

4.5.8.3 Maximum Feasible Mitigation

The third test in section 30260 requires a finding that the adverse environmental impacts of the proposed projects have been mitigated to the maximum extent feasible. As discussed in section 4.4.1 of this report, the Commission has determined that the projects are inconsistent with

---- -------~-~--~--~---~~~-~~---~~-~


Coastal Act section 30232 due to the potential for and resulting impact~ of an oil spill. However, upon the applicants acceptance of its permit, as conditioned, the Commission can find that the environm~ntal impacts generated by the project has been mitigated to the maximum extent feasible.

5.0 California Environmental Quality Act

As "lead agency" under the California Environmental Quality Act ("CEQA"), the State Lands Commission adopted an EIR (EIR No. 663, October 17, 1995) for the proposed projects. The Commission's permit process has also been designated by the State Resources Agency as the functional equivalent of the CEQA environmental impact review process. Pursuant to section 21080.5(d)(2)(i) of the CEQA and section 15252(b)(l) of Title 14, California Code of Regulations (CCR), the Commission may not approve a development project "if there are feasible alternatives or feasible mitigation measures available which would substantially lessen any significant adverse impact which the activity may have on the environment."

Although the Commission believes that these projects may generate adverse coastal zone impacts and pose a threat to the marine environment in the event of an oil or other hazardous liquid spill, the Commission finds that there are no feasible less environmentally damaging alternatives or additional feasible mitigation measures that would substantially lessen any significant adverse impact which the activities may have on the environment, other than those identified herein. Therefore, the Commission finds that the proposed projects are consistent with the provisions of the CEQA.

11\jml\subsea\E95combo.rpt

---·----------------------

34'21'00.

34.21'00"

34.24'00"

• H-1

............... .........

PRC 2879

----

• 3-6

Fagure 2.1. Locations of the subsea web to be abandoned in PRC 2879.

PRC 2207

PRC 3499

EXHIBIT NO. 1 APPLICATION NO. E-95-12

C Califomia Coastal Commission

..

!- )4'27'00"

PAC 2725

-:&4'25'00"

1

•

PAC 2726

-PAC 2206

-

-- PAC 4001

~F!Ei_

0 200 400 eoo METERS

,"" .,., .,..,. ____ ,....,. - --- ...... \.liE .---------.... ..----...........,_~-:::::----..:'-----.,. 3 tALE EXHIBIT NO. 1 1---.;._.-----r.--~ I

Figure 2.2. Location of the subsea well to be abandoned in PRC 2726.

APPLICATION NO. E-95-13

Cit: Califomia Coastal Commission

............

51,52, 53

•

PRC 1824

:w21'00" ...... ....., 3

............ ~~ PRC 4031 ............ .......... ...... __ --,

', '

Figure 2.5. Location of the subsea wells to be abandoned in PRC 1a2\.

16

HI'M•oo•

·: •. "'i • : ..

EXHIBIT NO. 1


C Califomla coastal Commission

.,

' .

I ------------------------------------------

..

l I I I I I

II

I

I I I I I

. . . . . • • . ·~ · .... :

Bull plug, to be installed by divers after tree is landed and tested.

Cross over 2" Grayloc hub down by 2" line pipe box up

2• Graylock clamps

2 1t,s• bore, 3000 psi WP gate valves with 2" Grayloc hub ends

2• Grayloc clamps

2 ,/,6" bore, 3000 psi / WP gate valves· with

2• Grayloc hub ends

2• Grayloc clamps

Tubing head adaptor Shaffer PN 325794

Use #8 clamps, with RX 49 seal ring to clamp tree to wellhead

J Figure T.4. Abandonment tree, Texaco Jade East well Nfl1.

I

I I I Subsea Well Abandonment Program

D4f.,.,.,,. #: .,Q. $i 4 A®: U .JC ) . t . . 4 4 ~ 4¥. .t 44§ • 944

EXHIBIT NO. 2

APPLICATION NO. E-95-12 E-95-13 E-95-14

at' California Coastal Commission

T-5

e - u: eo 4f •*"!' 4¥ ~·}ii'J4ZC4P4fD .,

~ .......

..... ........... che¥ronl C&IAesources • SwaBs • 10 ftowllnes.

SANTA BARBARA COUNTY

.....

SANTA BARBARA CHANNEL

Flgwe ES.1. Subsea wei abandonment and flowfme abandonment/removal plaMing area.

""'

~

. .....

EXHIBIT NO. 3 APPLICATION NO. E-95-12 E-95-13 F.-Q"i-1!..

~ catifomia Coastal Commission

.. ' .. »

To: CALlFORNin COASTAL COMMISSION

. This letter is in response to the State L~nds CoMmission

well head r"emoval progr'<U•l in the Gaviota area • . WE WANT THESE

REEFS PRESEHVED.

t. ECOLOGICAL AND BIOLOGICAL VALUE

1. The mat"'ine lifo on and associated with thesu man-

' rnatfa •"aefs is so much mC•i"'e ab~.u•,dant than natural reefs ar•d it

is MO&t difficult t~ believe without seeing. Look at these

man mado roQfs as eomp~rud to the natural ones in the State

Land' 5 video and see how mw:h mora <abundant they at"&.

·:::> ..... large stretched ~o the limit, those reefs provide S~NCTUARY

f"ot" tha fishe& and othe,... sea C''ea.tut'es. Tha , ish ,a,...., protected by these stryctul""es, out of reach of dragget"'s, gill

nat& and fot'" the rnost pal""t 1 the hook and line fisherman .als;o.

3. The fi&hes on tho~o reefs aro res;upplying th~

surrounding areas depletad by the years of unrestrained

SEISMIC !lurveys.

II. ECONOMIC VALUE

1. Sevet'al other fishe~'rnrzn and myself' h4V(! disc•Jssed

the c:ontY'ibut ions of' thliise reefs to oa.n"' incorl'les.. Af'tet" r.1ar.y

discussions, wo t'eel the minimum l.;:·sses to ba a.ppro)Cin1ately

health insurance for OUt' families, ,...etit"'ornont furrds, etc.

a. I

have been "using" thum Fo.., a0 yeat"'s, and to have these rec!t"s

EXHIBIT NO.4 APPLICATION NO.

E-95-12 t:·-9rn E-95-14

ttt' California Coastal Commisslcm

wran<:"hed f'roM us at this;. titne is Just ne-t V"i.gnt.

3. The "~vln"'age" prodi..\C:tive li'fe of oil and gas wells

are 20 yoars, 'at the tili1e tneuo walla eeauad to ba prodtJctive

they sttould have been pt"opet"'ly clomed in and removed, but no,

the state and oil companies sat on their butts for another 30

yea'l"'s and these walls becan1e massive fish producing rao'fs of'

considerable long term value.

III. USER GROUPS

1. Probably the largest user group is the sport

f'ishe'l"'man, launching theh" boats f'rort1 Gaviota, Santa Barbara,

an SC\nta SS.l''bar.a sport f'ishing boats. These all. ger.et .. ata

significant incomo to area business;as and 1""ecreaticm of' the

finost kind.

a. Commarcial fishermen also u•• the ree'f to produce

high value rock fishes and lobsters, etc.

IV. DISP~ACEMENT OF FISHERMEN

1. The removal of thas& reefs 1r.ti 11 create a large gap

in out" fishing resoureos. Principally in resupplying the

surrounding areas, and of equal impol""tancs, access to these

raaf during the Months of heavy wind when this is the ONLY

area available to the fisherMen to CONTINUE earning a living.

V. LIADILITV SOLUTIONS

1. Re-close in the wells, leaving the rnal""ine l i 1'G Ol"'l

these reafs as •Andisturbad .as possible.

\

..

:2. Post a bor'ld !SiMilar to the deal Exxon artd Mi"1S cant~2

to Or'l abando~ed deep well heads 1n their Santa Rosa t~act.

VI. FISHERY SOLUTIONS

cprofert"ed solution>

1. Leave everything as it i$.

a. Re-close the WGll heads with as little disturbanca

as possible to tha established Marine life.

3. Replaco the well neads witt, artificial resfs of . .

modern design to promoto fast marine growth and rapidly

re-establish fish schools.

4. SoMe progt"al'll to help the directly a'frected

risher1m:m get tnt"ough the re-esta.bl ishr11ent peri·~d.

Phi 1 Sc:hanof.t. F /V Tet"t'i' s Gale Cantral Coast Hook & Line nssoc (714) 898-78~~

10

• -

X

($tate2721)

Jade East No.1 Anchor Pattern

_____ ----.___.---\


£ California Coastal Commission

PRC <1001

CDOO .......... • a.-.11111 .._. . .,...... .... ....__

·~· .. ....... .......... ~ .... ~,..........., ........................... ....._ ..................... --.

Figure 4 Substrate features in the vicinity of Texaco Jade East Well N" J, PRC 2726.

.,

~ .... ~

331.00C7N +

330.CCID'N +

Nalllc 1. ~.,_on this s1a111:11 Cllllfarm willllhe

Cdlamia CoonfiMM ~ ~ Pnljeclion) z-Sin 1Mt. NAD 1V27.

2. HMIIIOIIDm ..., .... w.lllalionaiiCII!UiNd fnlm MOS 1MP11 1135A .... 1138, a11c11.a.

3. W-dep111We1151•e5tt. 4. W-deplh Well$2 • 15ft. 5. W-deplh Wei 153 • 15ft.

~ ~ !!! -

Figure H1.6. lmpad radii for spud can and anchor placement relative to geophysically· bottom, Well Nos. 51-53, PRC 1824.

I +


«<: California Coastal Commission

~:

i! r«ov Navlpllon Fix

0 ....

mJ ._... ....... .,__..,.._,.._. " ..,... c.----

Nolell.: 1. ~ .,_ oniiW IUiall Cllllllamlwllllhe

CeliiGnlia ~ ~ (Lamllllt Pllajecllan) Z..Sin ,_,HAD 1827.

2. ................ 8llquinlcl 11om McCieiiMd 111111 .._., ...... L

3.W..-...•1811t.

-----0

EXHIBIT NO. s APPLICATION NO. E

Figure H1.1. lmpad radii for spud can and anchor placement relative to geophysically· 1----------1 bottom, Well Nos. 5-6, 6-6, and 8-6, PRC 2879.

~ Callfomla Coastal Commission

-.

r--------------------------------------

..

• + •AnglepoiM

~.,-.·.·'··.·J llftock (F,_: CSA. 1911d)

Jr --•AnciiOr Placelllent

A -spud can Impact Radii

Noen:

+

Coonl~ sMwll on IIIia lkelcll c:onfllnn willlllle califamia CoonliMta $yst8m (l.amtleft Prajec:lion) z-5inteec.NA011r.Z7. w-de!llll= 275 tt.

'

I I

I • I

I I

I I

.. 110'

I TIAHSICTS - 7111 n/l.zt 11M

.. 0 0

~

-----0 -· 100'

EXHIBIT NO. APPLICATION NO.

E-95-12

Figure H1.2. Impact radii for spud can and anchor placement relative to geophysicall bottom, Well No. H-1, PRC 2879.

5

~ California Coastal Commlsston

STATE OF CAUFORNIA-THE RESOURCES AGENCY PETE WilSON, Governor

---------------------------------=------------------------------·· CALIFORNIA COASTAL COMMISSION 45 FREMONT, surrE 2000 SAN FRANCISCO. CA 9.4105·2219 VOICE AND TOO IA15190A·5200

DRAFT Memorandum of Agreement

Between the

EXHIBIT NO. 6

APPLICATION NO. E-95-12 E-95-13 E-95-14

California Coastal Commission, California Department of Fish and Game

and ({t' Califomia Coastal Commlsslon

\

United Anglers of Southern California

This Memorandum of Agreement (Agreement or MOA) is by and between the California Coastal Commission (the Commission), the California State Department offish and Game (DFG), and the United Anglers of Southern California (UASC), sometimes referred to as the Parties. The Parties agree as follows:

WHEREAS, Phillips Petroleum Company, Union Oil Company of California, ARCO Oil and Gas Company, CalResources, Chevron U.S.A. Production Company and Texaco Exploration and Production, Inc. (hereinafter referred to collectively as "the Applicants") have applied to the Commission to obtain individual coastal development permits to abandon permanently a combined total of23 subsea oil and gas completion wells and abandon-in-place/remove associated flowlines in state waters in the Santa Barbara Channel offshore of Santa Barbara County ("the Santa Barbara Channel Subsea Well Abandonment Program").

WHEREAS, on , the Commission 'granted to each Applicant a coastal development permit (E-95-9, E-95-10, E-95-11, E-95-12, E-95-13, E-95-14 and E-95-17) to abandon permanently a combined total of 23 subsea oil and gas completion wells and abandonin-place/remove associated flowlines in state waters in the Santa Barbara Channel offshore of Santa Barbara County.

WHEREAS, as a condition (Special Condition _) of its approvals, the Commission has required each Applicant to compensate for all project-related adverse impacts to hard bottom habitat t,hrough payment of a compensatory mitigation fee (hereinafter "the fee") which will be used to fund the construction of a new artificial reef or augmentation of an existing artificial reef in state waters within the Southern California Bight. The condition provides that the amount of the fee shall be calculated by multiplying by a compensation rate of $6.57 per square foot the total area of adversely affected or lost hard bottom as determined after comparing each individual project's independent pre- and post -abandonment surveys.

WHEREAS, the condition further requires that, should impacts occur, each Applicant shall pay its fee to the UASC within 30 calendar days of review and written determination by the Commission's executive director of the results of the independent pre-and post-abandonment surveys.

.. DRAFT Memorandum of Agreement Page2

WHEREAS, the DFG is the principal State agency responsible for the establishment and control of fishery management programs. The DFG is the State trustee agency with jurisdiction over the conservation, protection and management of fish, and habitat necessary for biologically sustainable populations offish species (Fish and Game Code, section 1802, 711.7).

WHEREAS, the DFG administers the California Artificial Reef Program for the purposes of ( 1) placing artificial reefs in state waters; (2) studying existing artificial reefs and all new reefs to determine the design criteria needed to construct artificial reefs capable of increasing fish and invertebrate production in waters of the state; and (3) determining the requirements for reef siting and placement (Fish and Game Code, sections 6420-6425).

WHEREAS, the DFG desires to assume the lead responsibility for the planning, siting, design and permit requirements for the construction of any new artificial reef or augmentation of an existing artificial reef in state waters using the fee( s) obtained from the Applicants.

WHEREAS, the UASC are a volunteer group of recreational anglers interested in preserving, protecting and enhancing marine resources and fishing opportunities.

WHEREAS, the UASC desires to secure and enter into a construction contract with a contractor to construct any new artificial reef or augment an existing artificial reef using the fee(s) obtained from the Applicants.

NOW, THEREFORE, in consideration of the benefits to marine resources of the State of California, the Commission, the DFG and the UASC agree as follows:

1. The UASC agree to receive any fees paid by the Applicants. Within 30 calendar days of receipt of any fee, the UASC shall deposit the funds in an interest-bearing account ("the compensatory hard bottom mitigation fund" or "fund"). These funds including all earned interest shall be expended by the UASC solely for reef materials, construction costs, and the UASC's administration of the fund (not to exceed 10% of the total collected fees).

2. Within 180 days of the date on which all fees have been paid to the UASC the DFG shall develop and submit for review and approval, by the Commission's executive director, a plan to spend the monies within the fund on either the construction of a new artificial reef or augmentation of an existing artificial reef within the Southern California Bight.

3. Within one year of approval by the Commission's executive director of a plan to spend the compensatory hard bottom mitigation fund, the DFG shall secure all necessary governmental approvals, including a coastal development permit, to construct a new artificial reef or augment an existing artificial reef within the Southern California Bight.

4. Within 90 days of either: ( 1) the granting of all necessary governmental approvals to construct a new artificial reef or augment an existing reef, or (2) approval by the Commission's executive director of a plan to spend the monies in the fund, whichever occurs later, the UASC shall secure and enter into a construction contract (the "Contract")

DRAFT Memorandum of Agreement Page3

w:th a contractor to construct either a new artificial reef or augment an existing artificial reef within the Southern California Bight. The Commission's executive director may for good cause grant an extension of the time deadline imposed by this section.

5. The Contract shall: (1) provide that the contractor will assume all liability for the reef material (e.g., quarry rock) until its placement in the designated location(s), and (2) specify that when the reef material touches the ocean floor at such location(s), the reef material shall become the property of the DFG.

6. Within two years of approval by the Commission's executive director of a plan to spend the monies in the fund, the UASC shall spend these monies to complete the construction of either a new artificial reef or augmentation of an existing artificial reef within the Southern California Bight.

7. The UASC and the contractor(s) must maintain Generally-Accepted Accounting Principles (GAAP), fmancial management, and accounting system and procedures which provide for (1) accurate, current and complete disclosure of all financial activity for the reef project, (2) effective control over, and accountability for all funds, property and other assets, related to the project, (3) comparison of actual ()Utlays with budgeted amounts, and (4) accounting records supported by source documentation. Annual financial reports showing current and cumulative financial activity must be provided to the Commission. All project records must be made available at any time for examination by the Commission.

The UASC shall retain all pertinent books, documents and papers, including financial transactions and supporting documents, and polic;:ies and procedures for the general accounting system, internal controls, and management practices for a period of three years following the date( s) of all final payment( s) under the Contract.

8. A failure on the part of any of the Parties to carry out the terms of this Agreement shall result in the following process. The party that believes another party is failing to carry out the terms of the Agreement shall bring the issue to the executive director of the Commission. If the executive director of the Commission cannot resolve the issue, the matter shall be referred to the Commission for resolution. The Commission may choose to seek ( 1) judicial enforcement of the terms of this MOA; (2) a full refund of any unexpended funds; or (3) other appropriate remedies.

9. This Agreement may be amended only in writing executed by all Parties.

.,

.· DRAFT Memorandum of Agreement Page4

IN WITNESS WHEREOF, the Parties have executed this MOA to this effect as of the date last signed below.

CALIFORNIA COASTAL COMMISSION

By: ________________________ _

PETER M. DOUGLAS Executive Director

CALIFORNIA DEPARTMENT OF FISH AND GAME

By: ________________________ _

JACQUELINE SCHAFER Executive Director

UNITED ANGLE.RS OF SOUTHERN CALIFORNIA

By: ________________________ __

JIM PAULK President

Date

Date

Date

DEPARTMENT OF FISH AND GAME 1•16 NINTH STREET P.O. BOX 9<U209 SACRAMENTO, CA 942..W.2090

(916} 653-7664

Mr. Peter Douglas Executive Director

January 26, 1996

California Coastal Commission 45 Fremont, Suite 2000 San Francisco, California 94105-5200

Dear Mr. Douglas:

~@~UWWif FEB 0 2 1996 (!}.) CALIFORNIA

COASTAL COJMMSSJCN

The purpose of this letter is to communicate the Department of Fish and Game's (DFG) intent to work cooperatively with the California Coastal Commission (CCC} and United Anglers-Southern California (UA) toward establishing a framework and agreement for artificial reef-related use of certain mitigation funds from offshore gas well abandonment activities which may become available as a result of CCC action.

current discussions among CCC, UA, and DFG staff have resulted in a conceptual framework which includes the following:

• Potential mitigation funds would be used to construct or augment artificial reefs in southern California in accordance with criteria established by the CCC and DFG.

• The DFG would undertake the planning·and permitting process necessary to construct or augment the reefs.

• UA would hold and disburse mitigation funds for reef construction at the direction of the CCC and DFG.

• Additional funds/materials may be sought to suoolement the mitigation funds.

EXHIBIT NO. 7 APPLICATION NO.

E-95-12 E-95-13 E-95-14

~ CaUfomia Coaltal Commlsslon

Mr. Peter Douglas January 26, 1996 Page Two

We are now working with CCC staff to develop a draft Memorandum of Agreement which will specify each participant's roll and responsibility in the timely and effective use of these potential mitigation funds. If you should have any questions or need more information during this process, please contact Mr. David Parker of my staff at our Long Beach office, 330 Golden Shore, Suite 50, Long Beach, California 90802, telephone (310) 590-5129.

cc: Ms. Alison Dettmer California Coastal Commission

Mr. Jim Paulk

Sincerely,

t~~i. C. F . Rays brook Q ~ Interim Director 4\...

United Anglers-Southern California

Mr. David Parker Marine Resources Division-Long Beach

~b Santa Barbara County Air Pollution Control District

November 3, 1995

Pugro West. IDe. SISS Olivas Park Drive Ventura, Califomia 930()3..7672

Attn: Simon A. Poulter

Subject: AbaDd.omnem of Subsea On Wells and Pipelines - PRC 2179, 2920, 2933, 2'793

Dear M:r. Poulter:

The Sama Barbara County Air Pollution Control District (SBCAPCD) received your three permit exemption requests dated June 12, 13 and 29, 1995. 1bese requests are for the abandomnent of 4 subsea oil wells at ISIOCfared pipelines on State Leases (PR.C 2879. PRC 2920, PRC 2933 and PRC 2793). these weJllllCl pipeline abancloaments, proposed by Unocal. CalResources and AR.CO, are

. part of a coordiDated. well aad plpeliDe "abandoDJDeDt proaram" which W111 deploy a single jack-up rig in the Sam.a Barbara Qannel. This jack-up rig wD1 be toWed to each well site until all wells in the abandonmem sequ.cmce are completed. 'Ihe estimated emissions for the subject subsea well and pipeline abarldonmeDt are u follows: 33 tpy NOx; 11.4 tpy CO; 3 tpy ROC; 0.8 tpy SOx; and 3.7 tpy PMIO. The "abaadomneut program" is scbed.uled. for caleadar year 1996.

We have demrmined that the use of the Cl'lpes on the jack-up rig and support vessels used for the abaDdoDIDIIIt of wells qualifies for the exemption spec1tled in Rule 202 C.2.g.

Please be adviaed that rhe SBCAPCD pennit replations are cummdy beinl revised and that this specific ex~ may be tiiiiOYeCI. If the "abaadoameD.t proaram" has not started, which means acma1 abandoameat of the wells, at the ftnl site md this exemption is removed by a tule change. the engine& may no louaer be .-pt from permit. 'Ibe rules in effect at the time of start-up would aovem the permit reqairemea.ts.

If you have.aay questioal reprdlDa this Jetter, please call me at (80S) 961--8814 or Phil Sheehan at (80.5)' 961-8876.

Sincerely,

'~~~ 1jerry Schiebe EqilleeriDI Supervisor

cc: Rick Owen. Unocal David Oreolt. CalResourcel Whit Hollis, ARCO PbD Sheehan, SBCAPCD APCD Exemption Pile Engineering CbroD File

m~~~~w~rrl' NOV • 6 199S L!!)

fUGRO • WEST, INC.

EXHIBIT NO. s D01.1rlaa W. Allard Air PcUution 26 Castilian Drive B·Z~, Goleta, CA 93117 Fu: 1!05-9(•1-8801 Phone:

APPLICATION NO. E-95-12 E-95-13

'.:•· 1.• "#,' • . :,> •• :. E-95-14

BlBG.-0S9-SB8 .:)NI '153M 4t' california Coastal Commission

•'

~ Santa Barbara County Air Pollution Control District

November 3, 1995

Chevron U.S.A. Production Company P.O. Box 6917 Ventura, California 93006

Attn: Keith D. Howell, Project Land Representative

Subject: Subsea Oil Well Abandonment Project- PRC 1824

Dear Mr. Howell:

'. 1 i•

'· .·--

"'- •'

The Santa Barbara County Air Pollution Control District (SBCAPCD) received your permit exemption request dated August 8, 1995. This request is for the abandonment of 3 subsea oil wells on State Lease PRC 1824. These well abandonments are part of a coordinated well and pipeline "abandonment program" which will deploy a single jack-up rig in the Santa Barbara Channel. This jack-up rig will be towed to each well site until all wells in the abandonment sequence are completed. The estimated emissions for the subject subsea well abandonment are as follows: 9 tpy NOx; 2.2 tpy CO; 0.7 tpy ROC; 0.2 tpy SOx; and 1.5 tpy PM10. The "abandonment program" is scheduled for calendar year 1996.

We have determined that the use of the engines on the jack-up rig and support vessels used for the abandonment of wells qualifies for the exemption specified in Rule 202 C.2.g.

Please be advised that the SBCAPCD permit regulations are currently being revised and that this specific exemption may be removed. If the "abandonment program" has not started, which means actual abandonment of the wells, and this exemption is removed by a rule change, the engines may no longer be exempt from permit. The rules in effect at the time of start-up would govern the permit requirements.

If you have any questions regarding this letter, please call me at (805) 961-8814 or Phil Sheehan at (805) 961-8876.

Sincerely, '\

~ k-·\1\.j J~-~ !Jerry Schiebe

Engineering Supervisor

cc: Phil Sheehan, SBCAPCD APCD Exemption File Engineering Chron File

Douglas W. Allard Air Pollution Control Officer 26 Casulian Drive B-2'. Goleta, CA 93117 Fax: M05-961-880 l Phone: 805-961-8800

·--

November 13, 1995

Ms. Susan Hansch

~ Santa Barbara County ~ Air Pollution Control District

California Coastal Commission 45 Fremont Street, Suite 2000 San Francisco, CA 94105-2219

~ ,··· .~;···· .·~~~;~:~·~·.:·

' :~~\{s. .... ;,j . .::. J'>' ,N 0'/1 7 199j;' '.!.:J

CAUfO~ir~~,\ COAST/,'.. CC,V.M\SSiC>l

RE: Subsea Well Abandonment and Flowline Removal Program on State Oil and Gas Leases in the Santa Barbara Channel (State Lands Commission EIR No. 663; State Clearinghouse No. 94121042).

Dear Ms. Hansch:

The Santa Barbara County Air Pollution Control District (APCD) would like to clarify for the Coastal Commission the air quality issues associated with the above referenced project. Specifically, the following major issues are discussed :

c> Project Background c> Basis for APCD Permit Exemption c> Project Emissions and Mitigation Measures c> Consistency with the 1994 Clean J\ir Plan for Santa Barbara County c> Deficiencies in the SLC Certified EIR

1. Project Background

The project involves the abandonment of old subsea oil and gas wells and the abandonment or removal of the flowlines associated with the wells. The wells and flowlines are located offshore Santa Barbara County in state waters on six leases. For the well abandonment phase, one jack-up rig and support vessels will move from site to site. Actual well abandonment activities will require approximately 1 0 months. Flowline abandonment and removal operations will require a work boat (or derrick barge) and may be completed before, concurrently with or after the abandonment of the subsea wells. This project phase is anticipated to require 9 1/2 months.

The project proponents are the following companies:

1. Phillips Petroleum Company 2. CaiResources (formerly Shell Western Exploration and Production Inc.) 3. Union Oil Company of California 4. ARCO Oil and Gas Company

Dougl:IS W. Allard Air Pollution Controlt 26 C:IStilian Drive B-23, C"rOiet:l., CA 93117 Fax: 805-961-880 I Phone: 805-961

EXHIBIT NO. 9 APPLICATION NO. E-95-12 E-95-13 .... ,..,. 14

C Calilomla COIIIItal comml8810n

-,

..

P;9;2 .. -··. --··--· .. ··-··· .... November 13, 1995

5. Chevron USA Production Company 6. Texaco Exploration and Production Inc.

The State Lands Commission, as the lead agency under CEQA, prepared and adopted EIR No. 663 on October 17,.1995. The EIR concludes that this project will result in significant adverse air quality impact~ unless feasible mitigation measures are implemented.

APCO staff provided data on emissions and mitigation measures. Curing the preparation of the draft EIR, we found the resulting EIR to be adequate. However, during the SLC adoption hearing in October, the mitigation language in the draft EIR was substantially changed without any prior public notice. The Final EIR required implementation of air quality mitigation measures only to the extent required by APCO rules and regulations.

2. Basis for APCO Permit Exemption

APCD Rule 202 C. 2. g (see Attachment 1) exempts from permit requirements piston type internal combustion engines on work-over rigs when the engines are used for the repair, workover, maintenance or abandonment of wells. The engines on the jack-up rig and support vessels qualify for this exemption. The APCD has granted this exemption to the five lessees who have applied for it. Only Texaco has not applied for this exemption.

3. Project Emissions and Recommended Mitigation Measures

SLC's EIR estimates that the project (abandonment work at all sites) will generate significant emissions as shown in the attached table (Attachment 2). If the project were not exempt from APCD new source review rules and regulations, these amounts would trigger APCD requirements for Best Available Control Technology, formal air quality impact analysis, and offsets. Feasible mitigation measures, including emission offsets, an innovative emission control program funded by mitigation fees and/or installing marine-vessel engine modifications were included in the EIR (Attachment 3). As mentioned above, the Final EIR required implementation of air quality mitigation measures only to the extent required by APCD rules and regulations.

4. Consistency with the 1994 Clean Air Plan for Santa Barbara County

CEQA Guidelines Section 15125 requires that a proposed project be consistent with adopted goals and plans. With respect to air quality, the applicable goals/plan is Santa Barbara County's adopted 1994 Clean Air Plan {CAP).

In order for a project to be consistent with the CAP, the project's emissions must either be included in the CAP's emission inventory or the project emissions mitigated to insignificance.

Sub ... Well Abandonment Project Page3 November 13, 1995

The emissions due to this project are not incl'-ided in the CAP 1. Consequently this project could only be consistent with the CAP if the emissions are mitigated.

5. Deficiencies in the SLC Final EIR

SLC's EJR concludes that the project will have significant adverse air quality impacts unless feasible mitigation measures are implemented. SLC applied the mitigation measures described in Attachment 3 and concluded that the significant adverse air quality impacts were reduced to a level of insignificance. Consequently, the EIR, when adopted by the State Lands Commission, classifies the air quality impacts as Class II.

As discussed under Project Background, the air quality mitigation measures would be implemented only to the extent required by APCD rules and regulations. Because this project is exempt from APCD permitting requirements, the mitigation measures would not be required by APCD rules and regulations. Consequently, the significant adverse air quality impacts would not be reduced to a level of insignificance and the classification of these impacts as Class II in the Final EIR is incorrect. The impacts should be classified as Class I, requiring the SLC to have made a Statement of Overriding Considerations when adopting the FEIR.

The second deficiency in the FEIR is the project's inconsistency with Santa Barbara County's 1994 Clean Air Plan, as discussed previously.

We hope this clarifies why the APCD continues to have reservations conceming this project proceeding without adequate mitigations. We are prepared to provide the project applicants assistance in obtaining the mitigations.

Sincerely~

~~cL Ron Tan, Air Quality Scientist Technology and Environmental Review

Attachments (3)

cc: G.K. Walker, State Lands Commission Pam Gross, Energy Div. , County P&D Peter Cantle, APCD TEA Project File {SLC: Subsea Well Abandonment) TEA Chron File

1 The project emissions are not Included in the CAP's point source inventory. While it could be argued that the project emissions are part of the CAP's area source inventory, the area source includes only sources with substantially less emissions than are emitted by this project.

. '

..

MORTON ASSOCIATES, INC.

Mr. Keith Howell, Chevron

Mr. Tom Kennedy, Phillips

Mr. Roger johnson, Texaco Mr. Hugh Herndon, UNOCAL

Mr. Mark T. Drumm, ARCO

Mr. Jeff Milton, CaiResources

SERVING THE PETROLEUM INDUSTRY

February 26, 1966

~~@~UWJS@ FEB 2 31996 CALIFORNIA

COASTAL COMM!SS!ON

Mr. Doug Allard, APCO, Santa Barbara County Air Pollution Control District

Enclosed find two (2) copies of the Subsea Well Abandonment Program Emission Reduc

tion Agreement. Please execute both copies, retain one for your files, and return one to me

for assembly and subsequent distribution of the completely executed document to all

parties.

Our objective is to have all signatures no later than March 6, 1996. If you cannot mee! this schedule, please call and advise when your executed copy will be transmitted.

Thank you for your cooperation and assistance in this matter.

Yours Very Truly,

E. E. Morton

cc: w/copies W. Dillon, S.B. County Counsel

S. Moore, SWARS Counsel S. Hansch, California Coastal Commission

D. Sanders, California State Lands Commission

F. Holmes, WSPA EXHIBIT NO. 10 ~PPLICATION NO.

-95-12 E-95-13 E-95-14

(((: California Coastal Commission

116 E. YANONALl ST., SUITE A • SANTA BARBARA • CA 93101 • TELEPHONE (805) 966-3556 • FAX (805) 966·6447

SUBSEA WELL ABANDONMENT PROGRAM EMISSION REDUCTION AGREEMENT

The Coastal Development Permit applicants for the Subsea Well Abandonment Rig Sharing (SWARS) program have reached agreement with the Santa Barbara County Air Pollution Control Officer {APCO) concerning mitigation of air emissions associated with the "Program". The program consists of all well abandonments reviewed in State Lands Commission (SLC) EIR No. 633 arid Gaviota wells reviewed in State Lands Commission ND No. 563. The terms of the agreement are outlined below.

1. Each Subsea Well Abandonment Program operator shall send a letter to the California Coastal Commission {CCC) modifying their application to incorporate into their project description all requirements set forth in the attached draft Phillips' letter to the CCC {see Attachment A which is incorporated herein by this reference).

2. · Subsea Well Abandonment Program operators shall provide $7 48,750 to fund programs to help mitigate short term air quality impacts of the subsea well abandonment program which will result in overall improved air q'-!ality beyond the life of the project. This payment will satisfy the operators' air quality mitigation obligation for the entire program and the long term air emission reductions will belong to Santa Barbara County Air Pollution Control District {SBCAPCD) and will be used to provide a long term clean air benefit. Apportionment of the payment shall be determined by the operators. The operators shall notify the District of the apportionment when it has been made.

3. The pre-survey work and the subsea well abandonment portion of the program is anticipated to be completed within a 12 consecutive month period. Pipeline/flowline abandonment/ removal operations shall be deferred to a 12 consecutive month period separate from the subsea well abandonment portion of the program.

4. The subsea well operators' program shall not be delayed by the execution of any of the air quality mitigation measures.

5. Based on the subsea well operators' commitments, the APCO will sign a letter acknowledging the mitigation provided by the subsea well operators, stating that the mitigation satisfies his air quality concerns with the program. The APCO will state

·. ..

..

his intent to strongly recommend and support the position that the current proposed Reg II and Reg VIII rule changes will not apply to this subsea well abandonment program.

6. Article 5 above is subject to a future favorable ruling of the APCO Board and subject to program completion by the end of 1998.

7. All emissions estimates are based on EIR and EIR-equivalent for Gaviota Mitigated Negative Declaration (NO) wells.

8. Operators shall employ a single rig utilizing Caterpillar 0·399 TA SCAC or other engines with equivalent or lower emissions than those described in the certified EIR. All subsea well operators participating in the program shall comply with all project descriptions and assumptions used to prepare the air emission estimates within the certified EIR and with this mitigation agreement.

9. These mitigation measures are program specific and are not intended to represent future policies or future mitigation measures.

10. Subsea well abandonment program operators will put forth a good faith effort to provide a workboat or crewboat for the APCD to demonstrate effectiveness of lean burn catalyst.

11. A deposit of $74,875 shall be paid to the SBCAPCD within 30 calendar days after all operators· receive their Coastal Development Permits (COP's). Final payment of $673,875 to the SBCAPCD will be paid no later than 30 days after all operators execute a binding rig contract. Operators shall not mobilize the rig to the first wellsite until 120 days after the date of SBCAPCD's receipt of the entire payment of $748,750.

12. SBCAPCD shall return the deposit 30 days from the date that the operators notify the District that the operators have surrendered their COP's because the program is not going to proceed.

13. Operators shall keep SBCAPCD informed of rig procurement progress, contracting progress and timing of rig mobilization.

14. Operators shall request the SLC to include their CCC COP commitments into the SLC Mitigation Monitoring Plan.

,

SWARS/ERAgreement 2 February 2 3. l 996

15. This Agreement may be executed in any number of counterparts, and each executed counterpart shall have the same force and effect as an original instrument and as if all of the parties to the aggregate counterparts had signed the same inst~ument. The signature page may be attached to another counterpart of this Agreement identical in form hereto but having attached to it one or more additional signature pages.

ATLANTIC RICHFIELD COMPANY CALRESOURCES LLC

By: ____________ By: _____________ _

Title: . Title: _______________ _

Date: Date: ______________ _

CHEVRON U.S.A. PRODUCTION COMPANY PHILLIPS PETROLEUM COMPANY

By: ___________ _

Title: ____________ _

Date: _____________ _

' TEXACO ExPLORATION AND

PRODUCTION, INC.

By: ___________ _

Title: ____________ _

Date: ____________ _

AIR PouunON CONTROL OFFICER

SANTA BARBARA COUNTY

AIR POLLUTION CONTROL DISTRICT

By: ___________ _ Date: ____________ _

SWARSIERAgreement

By: ____________ _

Title:. ______________ _

Date: ______________ _

UNION OIL COMPANY Of CALIFORNIA

By: ____________ _ Title:. ______________ _

Date:. ______________ _

3 February 23. 1996

•,

\

, .

.. DRAFT • • • PHilliPS lETTERHEAD • • • DRAFT

February __ , 1996

Ms. Susan Hansch California Coastal Commission Energy and Ocean Resources Unit 45 Freemont Street, Suite 2000 San Francisco, CA 941 05-2219

ATTACHMENT A

RE: Proposed Amendments to Coastal Development Permit (COP) Application No. __ E-94-17: Phillips Petroleum Companis Subsea Well Abandonment Project

Dear Ms. Hansch:

The Coastal Development Permit applicants fo.r the Subsea Well Abandonment Rig Sharing {SWA~S} program have reached agreement with the Santa Barbara County Air Pollution Control District {SBCAPCD) concerning mitigation of air emissions associated with the "Program 11

• The program consists of all well abandonments reviewed in State Lands Commission (SL() EIR No. 663 and Gaviota well abandonments reviewed in State Lands Commission NO No. 563.

The terms of this agreement are outlined below, and are provided on behalf of Phillips. By this letter, Phillips incorporates into the project description for Phillips' COP application the following:

1. Phillips shall pay its proportionate share of the applicants' payment to the Santa Barbara County Air Pollution Control District for programs to help mitigate Phillips' proportional share of the short term air emissions associated with the subsea well abandonment program. A total payment of $748,750 will satisfy the air quality mitigation obligation for the entire SWARS program and the resulting long term emission reductions will belong to SBCAPCD and will be used to provide a long term clean air benefit.

2. The pre-survey work and the subsea well abandonment portion of the program is anticipated to be completed within a 12 consecutive month period. Pipeline/flowline abandonment/removal operations shall be deferred to a 1.2 consecutive month period separate from the subsea well abandonment portion of the program.

3. Applicants shall employ a single rig utilizing Caterpillar 399 TA SCAC or other engines with equivalent or lower emissions than those described in the certified EIR. Phillips shall comply with all project descriptions and assumptions used to prepare the air emissions estimates within the certified EIR and with the mitigation agreement.

4. Applicants will put forth a good faith effort to provide a workboat or crewboat to SBC APCD for the purpose of demonstrat.ing effectiveness of lean burn catalyst.

5. A deposit of 1 0% of Phillips' total shall be paid by Phillips to the SBCAPCD within 30 calendar days after all operators receive their COP's. Final payment to the SBCAPCD will be paid by Phillips no later than 30 days after all operators execute a binding rig contract. Operators shall not mobilize the rig to the first wellsite until 120 days after the date of SBCAPCD's receipt of the entire payment of $748,750 from the applicants.

6. SBCAPCD shall return deposit 30 days from the date that the applicants notify the District that the applicants have surrendered their COP's because the program is not going to proceed.

7. Phillips shall request that all the above conditions be incorporated into the SLC Mitigation Monitoring Plan.

If you have questions or require additional information, please call Tim Murphy or me at (805) 966-3556.

Yours very truly,

E. E. Morton

cc: Mr. Dwight Sanders, CSLC Mr. Doug Allard, SBCAPCD

...

• . 03/18/96 15:32 UNOCAL COASTAL CA VENTURA ~ 914159045400

IJnoAI EMrB!f~DMeion Unocal Cofi)OtliiiOn 23231<t1011 Driw. P.O. Box 6176 Venb.tnl. CaWornia 93006 Telephone (805) 666-7600

March 18, 1996

N0.390 P001

RECEIVED MAR 1 8 1996

CO CALIFORNIA ASTAL COMMISSiON

EXHIBIT NO. 11

~s~Y~TION NO.

Ms. Scsan Hansch Califomia Coastal Commission Energy and Ocean Resources Unit 45 Freernont Street. Suite 2000 San Francisco. CA 94105-2219

Re: Proposed Amendments to Coastal Development Permit (COP) Application No. E-95-12: Union Oil Company of California. dba Unocal. Subsea Well Abandonment Proiect

Dear Ms. Hansch:

(((' California Coastal Commission

The Coastal Development Permit applica~ for the Subsea Well Abandonment Rig Sharin~ (SWARS) program have reached agreement with the Santa Barbara County Air Polluth.~ n Control District (SBCAPCD) concerning mitigation of air emissions associated with th. • "Program". The program consists of all well abandonment& reviewed in State Lands ~mission (SLC) EIR No. 683 and Gaviota weU abandonments reviewed in State Lands Commission NO No. 563.

The terms of this agreement are outlined below. and are provided on behalf of Unocal. By this letter. Unocal incorporates into the project desaiption for Unocal's COP application the following:

1. Unocal shall pay its proportionate share of the applicants' payment to the Santa Barbara County Air Pollution Control District for programs to help mitigate Unocal's proportional share of the short term air emissions associated with the subsea well abandonment program. A total payment of $748.750 will satisfy the air quality mitigation obligation for the entire SWARS program and the resulting long term emission reductions will belong to SBCAPCD and will be used to provide a long te nn dean air benefit

2. Tile pre-survey work and the subsea well aband~nment portion of the program is anticipated to be completed within a 12 consecutive month period. Pipeline/flowline abandonment/removal operations shall be deferred to a 12 consecutive month period separate from the subsea well abandonment portion of the prcgram.

Proposed Amndmnts. to Catl. Oev. Permit (COP) App. No. E-95-12: Union Oft Co. of CA, elba Unocal. SUbsea Wall Abandonment Project Page2

March 18, 1996

3. Applicants shall employ a Single rig utilizing CaterpHiar 399 TA SCAC or other engines with equivalent or lower emissions than those desctibed in the certified EIR. Unocal shall comply with all project descriptions and assumptions used to prepare the air emlsalona estimates within the certified EIR and with the mitigation agreement.

4. Appfants wiD put forth a good faith effort to provide a workboat or crewboat to SBCAPCO for the purpose of demonstrating eft'ectlveness of lean bum catalyst.

5. A deposit of 10% of Unocal's total shall be paid by Unocal to the SBCAPCD within 30 calendar days after all operators receive their COP's. Final payment to the SBCAPCO will be paid by Unocal no later than 30 days after an operators execute a binding rig contract Operators shall not mobilize the rtg to the first wellslte until 120 days after the date of SBCAPCD's receipt of the entire payment of $748,750 from the applicants.

e. SBCAPCD shall Altum deposit 30 days from the date that the applicants notify the District that the applicants have surrendered their COP's because the program is not going to proceed.

7. Unocal shall reqUMt that an the above conditions be incorporated into the SLC Mitigation Monitoring Plan.

If you hawe questions or require additional infonnatlon, please call Simon Poult::r, Fugro West. Inc .• at 8051650-7000. or me at 805165o-4506.

RR/cr\wp51\reynolds\plopsdam

cc: Mr. Dwight Sanders. CSLC Mr. Doug Allard. SBCAPCD

Yours very truly,

Union OB Company of california, dba Unocal

•.

••

'•

MAR-19-96 TUE 07:29 AH TEXACO E&P INC.

Texaco ExpJcnltOn aftd Proc:luc:tloft Inc

March 18. 1996

Ms. Susan Hansch

FAX NO. 805 648 8381

PO Bcx206 V81"1tura CA 93002

P.02

EXHIBIT NO. 11


Caflfomia Coastal Commission Energy and Ocean Resources Unit 45 Freemont Street, Suite 2000 San Francisco, CA 94105--2219

£ California Coastal Commission

RE: Proposed Amendments to Coastal Development Permit (COP} Application No. E95-13: Texaco Exploration and Production Inc. Subsea Well Abandonment Project

Dear Ms. Hansch:

The Coastal Development Permit applicants for the Subsea Well Abandonment Rig Sharing (SWARS) program have reached agreement with the Santa Barbara County Air Pollution Control District (SBCAPCO) concerning mitigation of air emissions associated with the "Program". The program consists of all well abandonment& reviewed in State Lands Commission (SLC) EJR No. 663 and Gaviota well abandonment& reviewed in State Lands Commission NO No. 563.

The terms of this agreement are outlined below, and are provided on behalf of Texaco. By this letter, Texaco incorporates into the projed description far Texaco's COP application the following:

1. Texaco shall pay its proportionate share of the applicants' payment to the Santa Barbara County Air Pollution Control Distrid for prcgrams to help mitigate Texaco's proportional share of the short term air emissions associated with the subsea well abandonment program. A total payment of $7 48,750 wiD satisfy the air quality mitigation obligation for the entire SWARS program and the resulting long term emission reductions will belong to SBCAPCD and will be used to provide a long term clean air benefit.

2. The pre-survey work and the subsea weD abandonment portion of the program is anticipated to be completed within a 12 consecutive month ~· Pipeline/flowline abandonment/removal operations shaD be deferred to a 12 consecutive month period separate from the subsea well abandonment portion of the program.

3. Applicants shall employ a single rig utilizing Caterpillar 399 TA SCAC or other engines with equivalent or lower emissions than those described in the certified EIR. Texaco shall comply with all projed descriptions and assumptions used to prepare the air emissions estimates within the certified EIR and with the mitigation agreement.

4. Applicants will put forth a good faith effort to provide a workboat or crewboat to SBCAPCD for the purpose of demonstrating the effectiveness of a lean bum catalyst.

Ms. Susan Hansch california Coastal CammisliOn 3118198 Page2

5. A deposit of 10% of Texaco's total shall be paid by Texaco to the SBCAPCO within 30 calendar days after au operators receive their COP's. Final payment to the SBCAPCD wiD be paid by Texaco no later. than 30 days after all operators execute a binding rig contract. Operators shall not mobirJZe the rig to the first wellslte until 120 days after the date of SBCAPCD'a nteeipt of the entire payment of $748,750 from the applicants.

6. SBCAPCD shaD ratum Texaco's deposit 30 days from the date that the applicants notify the District that the appfanta have swrendered their COP"s because the program is not going to proceed.

7. Texaco shaD request that aD the above conditions be incorporated into the SLC Mitigation Monitoring Plan.

If you have questions or require additional information, please call me at (805) 289-9387.

Yours very truly,

~ -·· \ ~j . ~·~ ..

Roger J. Johnson'

RJJ/pfg fllnlcll_1.ctoc.

cc: Mr. Dwight Sanders. CSLC Mr. Doug Alard, SBCAPCO Ms. Jeanne Lau. CCC

-CHEVRON.LAND-VENTURA TEL:SOS-658-4380

March20. 1996

Ms. Susan Hansch CaJifomia Coastal Commission Enei&Y and Ocean Resources Unit 4SPnummS~Sw~2~ San Francisco. CA 941 OS-2219

Proposed A.mendmena to Coaltal Development Penuit Applicatioa No.. E-95-14 (PRC 1824).

Mar 2 0 ;....::' 9::..:::6:.__--=...:1 2::......._;: 4:...:.7.......;.;.N.;;..o .:...· 0;.;0;...4;......;..P...;. . .;;..0 4....__

iii Chevron ChMOII U.I.A. PI'Odudloll ColftPIIlY s• eo...~y S4uln Driwl Vllllllra, Ctllifolnal i3Q)3 P.O.b6017 Venlu!a, Cllifornil83006

EXHIBIT NO. n APPLICATION NO. E--95-14

([(' California Coastal Commission

g.eyron p.S,A. Production Comrnmy's Subsea WeU Abandonment Project

Dear Ms. Han!ch:

The Coastal Development Permit applic:ants for the Subsea Well Abandonment Rig Sharing (SW ARS) program have reached agreement with the Santa Barbara County Air Pollution Control District (SBCAPCD) concerning mitigation of air emissions associated with the "Prosram". The program consists of all well abandonmcnts reviewed in State Lands Commission (SLC) ElR. No. 663 and Oaviota well abandonmenti reviewed in State Lands Commission ND No. 563.

The tenns of this agreement are outlined below, and are provided by Chevron U.S.A Production Company, a division of Chevron U.S.A Inc. (Chevron). By this Jetter, Chevron incorporates into the projC(;t description for Chevron's CDP application the foUowing:

I. Chevron shall pay its proportionate. share of the applicants' payment to the Santa Barbara CounLy Air Pollution Control District for programs to help mitigate Chevron's proportional share of the shon tenn air emissions associated with the subsea well abandomneot proaram A total payment of $74&. 750 wiD satisfY the air quality mitigation obligation for ·the entire SW ARS program and the raulting long term emission reductions will belong to SBCAPCD and wll1 be used to provide a long term dean air benefit.

2. The pre-survey work and the subsea wc11 abandonment portion of the program is anticipated to be completed within a 12 consecutive month period. Pipcline/.flowline abandonment/removal operations sbaU be deferred to a 12 consecutive month period separate fiom the subsea well abandonment portion ofthe program.

3. Applicants sbal1 employ a sinale rig utilizing Caterpillar 399 TA SCAC or other engine~ with equivalent or lower emissions than those describocl in tho certified EIR. Chevron shall comply ~ aU project descriptions and assumptions used to prepare the air emissions estimates within the c:ertified EIR. and with the mitigation agreement.

• . ..,q :ll· I !•:.' I iII II .I ,, I" t I • IlL t I I

CHEVRON.LAND-VENTURA TEL:805-658-4380

Propotecl Ameadments to Coastal Development Permit Application No. E-9S-14 (PRC 1824) Mvcb 20. 1296

Mar 20.96 12:47 No.004 P.OS

4. Applicants will put forth a soocl tiith etrort to provide a workboat or crewboat to SBCAPCD fbr tbe purpose of dOIIIDDitrlting effectiveneaa oflean bum catalyst.

5. A deposit ot 10010 of Chevron's total shall be paid by Chevron to the SBCAPCD within 30 ca1endar days after all operatOrs receive their COPs. Fmal pa.ymcmt to the SBCAPCD wiD be paid by Chevron no later tblll 30 daya after aD operators execute a bindios ria contraet. Operators sball not mobilize the ria to tho first welllite urd 120 daya aft« the date of SBCAPCD'a receipt of tho entn payment of$748, 750 &om the applicants.

6. SBCAPCD shall return deposit 30 days &om the date that the applicawa notify the District that tho appticents have SU11'CIIdercd their COP's because the program is not 8oina to proceed.

7. Chevron shall request that all tbe above conditions be iDcorporatod .no the SLC M'atipti011 Monitorina Plan.

If',au have questioDs or require aclditioaal iutonnation, pleue caD me at (80S) 658-4537.

Youn very truly.

~J(~

ICDH/ooaubaea.doc

cc: Mr. Dwight Sanders, SOC Mr. Doua Allard, SBCAPCD

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